ML20024D152

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Testimony of M Tuckman,L Snow & M Green in Charlotte,Nc. Pp 1-152
ML20024D152
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 05/17/1983
From: Matthew Green, Snow L, Tuckman M
DUKE POWER CO.
To:
References
NUDOCS 8308030219
Download: ML20024D152 (152)


Text

/ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In Re:  :

DUKE POV'ER COMPANY, Et A1.  : DOCKET NUMBERS (Catawba Nuclear Station  : 50 413 Units 1 and 2)  : , 50 414 l

MAY 12,1983

,- 9:30 A. M.

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DEPOSITIONS O_F:

MICHAEL TUCKMAN LOWELL SNOW MICHAEL GREEN 07 95 ,

o e i

l l Evelyn Berger Associates 8308030219 830512 STENoTYPE REPORTING SERVICE PDR ADOCK 05000413 p o sex i.44, .

l T PDR CN ARtoTTE. NORTH CAROLIN A 24219 '

2 1 A PPE AR ANC ES:

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2 ROBERT GUILD, ESQ.

C ha rle s ton, S. C.

3 Couns el on Behalf of int e rvo no r, P alme tt o 4 A lli a n c e , Incorporated 5 D E B E VOIS E & LIB ER M A N, ESQS.

W a s hin g t o n, D. C.

6 BY:

J. N.ichael M cG a r r y, III, Esq and Anne W. C ottin gha m 7

ALBERT V. CARR, JR., ESQ.

8 R ON A LD L. GIBSON, ESO.

C ha rlo tt e, N. C. .

9 Counsel on B e half of A pplicant, Duke Powe r 10 Company 11 A LSO PRESbNT:

12 Roger W. Q u e lle tt e Duke Power Company 13 Mike C hild e r s 14 Duke Power Company 15 Mic ha el F. Lowe P alm e tt o A llia n c e , Incorporated 16 Nina Frankel 17 Lee Ann Kornegay Electronic Recorder 18 P alm e tt o A lli a n c e. Incorporated 19 l

20 21 22 23 24 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE, NORTH CAROUNA

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2A 1 I N D E X t

2 EIT N E S S E S DIR E CT CROSS 3 Michael Tuckman 8 147 4 Michael Green 20 147 5 Lowell Snow 8 14 7

. 6 7

8 9 '

10

_ _ _ . E X H I B I T S 11 12 NUMBER DESCRIPTION PAGE i

13 Exhibit Number 1 November 2,1982, letter 61 14 15 16 17 18 19 20 21 22 23 24 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

- e-

3 1 T he Depositions of h.ichael Tu c kma n,

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2 Lowell Snow, and Nichael Green are taken at th e 3 Of fi c e s of Duke Power C om pa ny, C ha rlo tt e, North 4 C a r olina, on this the 12th day of M a y, 1983, in the 5 presence of R obe rt G uild , Attorney on behalf of the

. 6 In te rv e nor; and J. Michael M c G a r r y, III, A nn e ' W.

7 C ottin gh am, A lb e r t V. Carr, Jr., and R o nald L.

8 Gib s o n, Attorneys on behalf of the A p plic a n t.

9 It is agreed that L'i n n B. Gilliam, Notary 10 Public in a n'd for the State of North C a r o li n a , may 11 take said D e p o s itio n s in m a c hine s ho rthand and 12 tra n c e ribe the same to t y p e w ri tin g.

i 13 kR. MC G A RR Y: Let the Record r efle ct 14 the same people who attended the prior D ep o s ition are 15 in attendance with two a d ditio n s , hike Child e r s and 16 who me ve r you have right here.

17 We are here this mo rnin g to take the 18 Depositions of Mr. L o we ll Snow and Michael Tuckman.

19 Bef o re commencing with those D e po sitio n s , I would 20 li k e to note several things in the transcript with 21 respect to the S tipula tio n co n c e r nin g taking of the 22 Deposition by othe r tha n st eno gra phic means.

23 A S tipula tio n was ente red into by Palmetto

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24 and the A p plic an t s . T ha t Stipulation is contained in 25 a Deposition of h.ary Birch taken ye s te r day, and it ir EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

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cgreed there is no need to repeat that Stipulation.

2 That Stipulation remains in eff ect with 3 respect to the A pplic a nt's comment as to the lack-of 4 No ti c e of D epo sition for it s Witn e s s e s , and with 5

recpect to the A pplica nt's p o sitio n that they are

. 6 a c c o m m o d a tin g Paimetto in p r o vidin g Witne s s e s for 7

D e p o s iti on s .

8 The comments contained in the D e po sition 9 of Aary Birch are a p p lic able 't o this D epo s ition.

10 /. third point concerne documents. There II was some discussion about the a v aila b ilit y of docu-12 We w o u ld like ments in A a ry Bir ch' c Deposition.

13 this transcript Record to reflect that the e n ti r e FSAP 14 for C atawba ic in the room, and all necessary docu-15 ments that were in the Discovery Room of Duke Powe r 16 Company are a v ail a b le in this room today.

" Two other points, this D epo sition was to I8 consist of a p a n el of three Witne s s e s . The third is 19 who is knowledgeable of the

f. r . L.ichael Green, 20 .

structural analysis.

21 Secause of a schedule c o nfli c t, and we 22 went quite late yesterday with h< a r y Birch, he is not '

23 a vc ila bl e today, and we w'i l l work together to 24 reschedule his D e p o s itio n perhaps for next konday or 25 next F rida y.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NOPTM CAROUPee

5 1

La s tly, I would l i. k e the Record to r e fle c t 2

in a tt endanc e at this D e p o s itio n are those p e o ple 3

whose names were reflected in h;ary Birch's 4 D e p o sition.

5 In addition, two other individuals are in 6

attendance at this D e p o s ition. First is Michael 7 C hild e r s, an employee of Duke Power Company who is 8

acsigned to the Design E n gin e e rin g D e partm ent; and 9

he is an E n gin e e ring A r s o 'c i a t e .

10 I believe Pa lm et to A llia n c e has an additional 11 r e pr e s entative.

12

g. S . FE ANKEL: Nina Frankel.

13 1: R. GLILD: Ms. F ra nkel is a s sis ting us 14 in taping the D e p o s itio n.

15 16 MICHA E L TUCKMAN a nd LO W ELL SNOW, 17 having been fi r s t duly aworn to tell the truth, was  :

18 examined and te s tifie d as follows:

19 MR. G UIL D: .V y name is R obe rt G uild. I 20 met you before, h: r . Tuckman and Mr. Snow. I am 21 C oun s el and Intervenor in the li c e n si n g case, as 1 22 am sure you know, and I would like to ack you some 23 que s tion c in p re paration for our case on the s u bj e c t 94 of C o nt e n tio n Nu m be r 16 whic h has been A d tn i t t e d .

25 L! r . Tuckman, both g e n t l e n. e n , a c t u r.11 y ;

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CDsARLOTTE. NORTM CAROLINA

6

. 1 I would ask since both of you a.r e coing to be e p e a kin g

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2 interchangeably in response to come qu e s tio n s , that 3 you a ll o w the other to fi ni s h b ef or e you jump in.

4 We would hare a bit of dif fic ulty s o rtin g 5 out the voices on our ta p e. It will be Palmetto

. 6 A llia n c e 's R ec ord of the Deposition, and I will tr y 7 to slow down so my voice will be dis tinc t, and I 8 would ask you to do so as w e ll .

9 It might be h e l p f'u l if you w r. n t to inter-10 ject an answer, to id entif y yourself before you speak--

11 1.11 c h c c 1 Tuckman, let me add a few c omm ent s --that 12 would h elp us cla rif y th e answers.

13 I wa nt to try to obtain some in f o r mation on 14 the subject of our C o n t e n tio n 16. .I f qu e s tio n e 1 ask 15 are not clear, the terms I am using rre unclear or 16 I am not m a kin g mys elf und e r s to od, please feel free 17 to stop and ask for c la r ifi c a tio n.

18 Ask what I mean by a term; othe rwis e, I 19 will understand and as sume you have understood the 20 q ue s tio n and your answer is responsive to the qu e s tio n 21 the way it was csked.

22 I would like to be in f o r ma l, so if I'm not 03 and there is an g e ttin g to the heart of the matter, 94

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obvious a s sumption or mis tak e of fact, please feel 25 free to correct me and help us so we can get down EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA t

Tuckman, Snow - Direct 6 1 to the actual inf o r m a tion needed.

2 3 D1R EC T EXA MIN A TION 4 BY MR. GUILD:

5 Q Now, hr. T uckman, I b e lie v e that you

. 6 participated in a n's w e r in g some of the e a rli e r 7 Inte rr o gato rie s and R e qu e s t for P r o d uction file d by 8 p alm e tt o A llia nc e on the cubject of our C ont e ntio n 16; 9 didn't you?

10 MR. TE CKM AN: Yes, sir; tha t 's correct.

11 MR. GUILD: C oun s el, I have two 12 documents in front of me. Can we s tipu-(~ 13 late that Mr. Tuckman participated in 14 r e s pondin g to answers that are reflected in 15 both of these documents ?

16 MR. CARR: Let me check the file, 17 Bob. I know he did on the first one. Mr.

18 Tuckman did not p a r ticip at e in r e s po ndin g 19 to your f ollow up Interrogatories.

20 Our Response to that was file d on 21 3/25/83. He did participate in the 22 R e s pon s e, our Response to your initial 23 Interrogatories, which were fil e d Octobe r 19, 24 1982.

M I b elle ve that Roger would be the EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. enORTM CAROUNA d

v - , -- - - .

T uc kman, Snow - Direct 9

,. I appropriate Duke person who is r e s po ns ible 2 for the f o llo w up Responees on IJ u m b e r 16, 3 your Response dated N. arch 25; Roger 4 O u e lle t t e and Mr. C hilde r s .

5 I can just go on to clarif y, I don't

. 6 think any of those f ollow up Interrogatories 7 related to the area that Mr. Tuckman is 8 responding to.

9 -

10 GUILD:

BY MR.

11 Q Mr. Tuckman, have you had an opportunity 12 to e x a min e the Discovery Responses that we have been

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13 r ef e r rin g to?

14 Let me show you a copy dated March 25, 15 1983 (in dic a tin g); and is the document that Roger 16 O u e lle tt e . -

17 MR. TU CKM AN: Yes, I'have r e vie w e d that .

18 Q Mr. Snow, I understood that you have not 19 f o rm e rly participated in preparing R e s pon s e s to 20 P a lm e tt o A llia n c e 's que s tio n s on the subject of 21 C ont e ntion 16 ; that is correct, is it not?

22 MR. SNOW: That is almo s t correct.

23 Q Help n.e understand what your role hac 94 been.

25 M R. SNOW: I think t h at one of the EVELYN BERGER ASSOCIATES. $7ENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

Tuckman, Enow - Direct to 1 i n d i v i d u c. l t. who reports to me in a s up er vis o r y way 2 has contributed to the f ollo w up Interrogatories.

3 Q V/ h o would that have been, sir ?

4 L. R . S N O V/ : That would be Jim T ho r n t o n.

5 C Mr. Snow, h z. v e you had an opportunity to

. 6 examine the two Nesponses that I had reference to, 7 P alm ett o A llia nc e 's In t e r ro gato rie s on C ont e n tio n 16 ?

8 M R. S N O V!: Yes.

9 Q For the Record, g e'n t l e m e n , fi r s t Mr.

10 T uckman cnd Mr. Snow, identif y your present p o s ition 11 with Duke Power C ompany; and if you would, briefly 12 s um maric e your professional tr aining and experience,

?,

13 please.

14 MR. TUCKM AN: My name is Nike Tuckman .

15 I pr e s ently hold the position of Superintendent of 16 T e c hnic al Services Operator at the Catawba Nuc le a r 17 Power S t a tio n, a p o sition I've held for a pp r o xim a te ly 18 five and a -h alf years.

19 You asked about e duc atio n ?

20 Q Give me your work experience prior to that 21 job, kr. Iuchman.

no -

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MR. TUCKMAN: Prior to that po sition I 93

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worked with Duke for about four years as Lead 24 Licensing Engineer on the Oconee f a c ility.

25 Prior to that I spent three years at O 2. k EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA

Tuckman, Snow - Direct 11 1 Rid ge, Tennessee, Ele ctric al Engineer for U nion

( l 2 Carbide C o r po r atio n; six yeare of nuclear Navy 3 experience and prior to that, c olle g e.

4 I have a B a ch elo r's Degree in El e c t ric al 5 En gin e e rin g, G e o r gia Tech, and graduate work in

. 6 Electrical E n g i n e 'e r i n g from th e U niver sity of 7 Tennessee.

8 Is that sufficient background?

9 Q Yes, Mr. T u c k m a n',' if you would, g e ne r ally 10 describe what your dutie s are as S u p e r vi s o r of 11 T ec hnic al S e r vic e s at C a tawb a.

12 MR. TU CKM AN: I am responsible to the

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13 plant M ana g er in providing t e c hnic al services to th e 14 f a cility. I have four maj o r areas of concern:

15 Health Physic s, Chemistry including r a dio a c tiv e wa s te 16 tr e a tm e n t, P e rf o r m a nc e En gin e e rin g, including 17 Reactor E n gine e rin g, Licensing P roj e ct s, and 18 Emergency Pla nnin g.

19 Q Mr. Snow, if you wo uld, sir, your full 20 name, your present po sition with the c o m pany, and 21 s imila r ly, a brief resume of your professional 22 experience and training, sir.

23 MR. SNOW: My name le Lowell Snow, and 24 I am cu r r e n tly the Supe r viso r of the Nuclear Sub Gro up 25 in the M e ch a nical Nuclear Division of the Design EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

Tuckman, Snow -

Diroct 12 1

E n gin e e rin g D e pa r tm ent.

2 I have held that p o s iti on for a p p r oxim a t ely 3 three years.

4 Q Slow down and try that one more ti m e.

5 What ic~ your f ormal title ?

6 MR. SNOW: My f ormal title is D e sign 7 E n gin e e r II, that is Roman Num e ral II, 8

Give me that de s c ription of your position 9 one m o r'e time, if you wo u5d.

10 jM R. SNOW: I s u p e r vi s e the Nuclear Sub 11 Group, M e ch a nic al Nuclear Division, D e sign 12 Engineering D e pa r tm en t.

t 13 Q A ll right, sir; and your previous p o s itio n s 14 with the c o m p a ny, sir ?

15 MR. SNOW: I've held this p o s itio n for 16 a p p ro xim a t e ly three years. For the three years prior 17 to that tim e , approximately, I was th e Supervisor of 18 the C atawba Su p po rt R e s traint D e si gn Group.

19 Five years orior to that tim e I supervised 20 a group that had r e s p o n s ibility for C atawba Fluid 21 S ys tem e Design on the nuclear side of the pla nt.

22 Four years prior to that I supervised a .

23 group that was responsible for R a dia tio n i. n a l y c i s ,

o4 which means e f flu e n t s and shielding analysis.

3 Prior to that I was in c olle c e. I have a EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

T uc kma n, Snow- Di re ct 13

, 1 Bachelor of Science Degree from the U nive r sity of s

2 T enne c c ee in_ Nuclear Engineering; and I have a 3 M a s te r 's Degree f rom the U niv e r sity of South 4 C a r olin a in h.echanical E n gin e e rin g.

5 I have completed, rather, I have passed

. 6 p r e limi n a r y exam s for PhD candidacy at the 7 U nive r sity of South C a r olin a, although that degree is 8 not completed.

9 Q W hat fi e l d is that?'

10 MR. SNOW: Mechanical En gin e e rin g.

11 Q C on tinu e.

12 MR. SNOW: I'rn a R e giste re d Pr of e s sion al

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13 E n gin e e r in North and South C a r olin a.

14 Q M r. S no w, if you would, b ri e fly d e s c rib e 15 your present duti e s and th e po sitio n you now hold 16 with the c om p a ny.

17 MR. SNOW: My group has five fun c tion s:

18 They are Fluid Fuels C riti c a lity, Radioactive 19 E f flu e n t s . -

20 I have r e s po n s ibility for the M e c ha nical 21 Nucle ar Design inte r f a ced with the SR A L Division.

22 O W ould you explain that acronym ?

23 MR. SNOW: Safety, R eview and Analysis 24 Division, and Licensing I think is in th e r e; S af ety, 25 R e vi e w, A naly si s and Licensing.

. m.... . m oc,m .. m ~om n~.. - =.c~ y . - c - ~~

Tuckman. Snow - Direct 14 1

s We have a G en e ric Engin e e ring f un c tion 2

which includes the cleaning of the Oconee system 3

generators and the fifth area of r e s pon sibilit y is the 4

r eview and r e c o mm e nd a tion s fo r RADWASTE systems 5

modification s on all s tation s.

6 Q Mr. Snow, if you would, sir, describe 7

how your group's r e s p on s ibiliti e s or personal 8

r e s p o n s ibilitie s relate to those of a Witne s s we 9

que s tion ed yesterday, Ms. M' a r y Birch.

10 hi R . M CG A R R Y: I object to that 11 que s tion. Mary Birch's subject was 12

, m o nit o rin g; and M r. Snow is here to t e s tify

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13 about the spent fu e l pool.

14 Any objection is based upon relevancy ,

15 There is no relevancy.

16 MR. GUILD: What I' m trying to under -

17 stand, I am not in t e ndin g to pursue a 18 monitoring subject with the Witne s s ; but 19 l' m t r yin g to unde r s tand where the RADWAS TI 20 r e s p o n s ibilitie s interfaced with those 21 described by h: r s . Birch yesterday so I 99

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can understand the area of the Witne s e '

93 e xp e r ti s e and his ability to respond to 94 que s tion s.

25 MR. M CG A R R Y: I will s till maintain EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTM CAROUNA

Tuckman, Snow - Direct 15 1 the obj e ctio n, but I will not ask the 2 W itne s s to refuse to answer the qu e s tio n.

3 4 BY h R. GUILD:

5 O I understood f ro m Ms. Birch's te stimony

. 6 she has r e s pons ibilitie s in the R A D WASTE. How 7 would your r e s p on s ib iliti e s dif f e r and interrelate?

8 MR. SNOW: The r e s po n s ibility that hi a r y 9 has is associated with the P r6 du c tio n D e p a r tm e nt; 10 and the r e s p o n s ibility that I have is a s sociated with 11 the Design D e pa rtm e nt.

12 It is simply al on g tho s e line s that th e

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13 corporate organization is divide 6. We don't do the t-14 same things.

15 Q . G e n tle m en, to r ef r e sh your recollection 16 I want to direet your attention to the text of 17 C ontention 16.

18 I'm showing you Page Five of a do cume nt 19 that has p r e viously been referred to as A pplic a nt's 20 Responses to third set of Inter ro gato rie s a nd R eque s t 21 to Produce dated O c tob er 19, 1982 (indicating).

22 If you would take the time to '

e xamin e 23 thct sin gle- s p a c e d paragraph indicated on that page, f

24 have you b oth had a chance to see that before today, 25 Contention 16?

EVELYN SERGER ASSOCIATES. STk NOTYPE REPORTING SERVlCE. CHARL83ETE. NORTM CAROUNA o

T u c kman , Snow - Direct 16 1 M R. SNOW: Yes, sir.

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2 M R. TU CKM AN: Yes, sir.

3 Q G e ntleme n, what are the company's plans 4 with respect to the storage of no n- C at a wb a fuels at 5 the C atawba Nuclear Station in s p e nt fuel storage

. 6 f acilitie s ?

7 MR. MCGARRY: In respect to the 8 plans, that is irrelevant to the C o nt e ntio n.

9 It focuses upon t h e' ' i m p a c t associated with 10 the storage of Oconee and M c G uir e spent 11 fuel at C a t a wb a.

12 MR. GUILD: I would ask the

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13 Witne s s e n to answer the qu e s tion s, 14 MR. MCGARRY: We will direct the 15 Witne s s e s not to an s w er th e qu e s tio n.

16 MR. GUILD: W e ll, Mr. M cG a r r y, at 17 that point we may want to adjourn the 18 D e p o s ition. We certainly think it is less 19 than fruitful to pursue further qu e s tionin g 20 of the Witnes s e s where you have o bj e ct ed 21 to the m.

22 You directed them not to respond to 23 the f u nd am e ntal' qu e s tion which forms the

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24 basis for whether or not the A p pli c a nt can 25 safely perf o rm the fun c tion s .re p r e s e nte d EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVtCE. CHARLOTTE. NORTH CAROLINA r

17 I by the man to whom the qu e s tio n is directe d, i

2 so I think perhaps we ought to at least 3 consider wh e th e r or not it ic f ruitf ul to 4 Pursue the m att e r.

5 Le t's take about a fiv e - min u t e recess,

. 6 if we c'a n .

7 (Whereupon, the D e p o s iti on was 8 adjourned for a b rief recess, after 9 wh ic h the f o ll'o wi n g proceedings were 10 had:)

11 12 MR. M CG ARRY: I would li k e to put

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13 on the Record the A p plic an t 's po sitio n with 14 respect to the matter that caused the 15 D e p o s iti o n to be adjourned for the period of 16 time it has.

17 We have presented three Witn e s s e s.

18 and I would like the Record to r e fle c t that 19 Michael Green is now in attendance at the 20 D e p o s ition. These Witne s s es are prepared 21 to discuss the heat lo a d c ritic al ity- and 22 fuel h a n dlin g.

23 It is our view these areas of te s timon y 24 are consistent wit h the B o a r d 's Order of 5 July 8, 1982, which excluded t ra n s p o rt a ti o n EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

18 1 and the Cascade Plan as an aspect of this

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2 C o n t e ntion.

3 R a th e r, the Board in its July 8th ' 82 4 Order, e p e cific ally lended the C o nt e n tion 5 to relate to the storage of r a dio a c tiv e fuel

, 6 a s s emblie s at other f a c ilitie s than Duke a nc, 7 C a t awba, the Cascade Plan othe r wis e known 8 as Du ke 's tr an s - s hip m e nt plan, was raised 9 with respect to Cohtention D E S 10 and 19.

10 That aspect was e x c lu d e d by the 11 B o a rd 's Order of February 25, 1983. The 12 la st position that we would lik e the Record 13 to reflect is t h a t' the p o sitio n that we take 14 today is c on si s tent w it h the po sition we ha ve 15 taken in response to Interrogatories.

16 Palmetto A lli a n c e has had an oppor-17 tunity to file a Motion to Compel with 18 respect to those p o s ition s, and indeed was 1

p r o vid e d the o p p o r tu nity by the Board in t

l 19 20 its Order I b e li e v e of .D ec embe r let or 22n d l 21 of 1982.

22 P a lm etto A lli an c e has not to sought l

23 to compel A p plic an t's obj e c tion s , which aro l r 24 c on si s te nt with the o bj ec tion we take t o da y.

25 That concludes the s t ate m e nt.

i EVEi,TN BERGER ASSOCIATES. STENOTYPE REPORTING EERV8CE. CHARLOTTE. NORTH CAROLINA m,m. .-_

l 19 l l

l 1 NR. GLILD: h' r . 14cGarry, of c our s e , I

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2 we discussed off the R ecord it is Palmetto l 3 A llia n c e 's intention to pursue the right of 4 the que s tion which was asked, su bj ect to 5 the then a v a il a bili t y of the Witne s s es.

. 6 For c l a r i t y, sir, would we stipulate 7 hi r . G re en w o uld respond likewis e and you 8 would direct him not to answer?

9 MR. hi C G A R R 'Y : The A pplic ant's 10 o bj e c tion wo uld apply to Mr. Green also, 11 yes, kr. Guild. ,

12 MR. GUILD: An understanding that 13 the suggested rules and authority that 14 govern the posture we find ourselves in in 15 the D e p o s itio n at this point, s eem s to give 16 us, Palmetto A lli a n c e , the o ption of either 17 a dj o u r nin g the Deposition and seeking a 18 R ulin g on what we b e li e v e to be the correc t 19 po s ition we have asserted, or to continue 20 with the D e p o sitio n.

21 We have discussed some areas which 22 we b e li e ve the Witne s s e s are capable of 23 addressing, which I un de r e ta nd C oun s el 24 b e li e v e s are properly the s ubj e c t of 25 D e p o s iti o n q ue s tio n s , and I will make an EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE. NosFTH CAROUNA w - - - r-

4 Tuckman, Snow, Green - Direct 20 1 effort to pursue those subjecte at this 2 point.

3 4 MICHAEL GREEN, 5 having-been fir s t duly sworn to tell the truth, was

. 6 e xa min e d and t e s t'1 fi e d as follows:

7 8 DIR EC T EX A MIN A TIO N 9 BY M R. GUILD:

10 Q Mr. Green, I have asked your two c o ll e a gu es

~

11 to go through this little r e gime nt, and I wo uld like 12 you to do the same: State your present position with

(

13 the company and give us a brief re sume of previous 14 p o s iti on s held and your p r of e s sio nal and academic 15 background, sir.

16 MR. GR EEN: P r e s ently Su pe rvis in g De sign 17 E n gin e e r in the Civil Environmental Division of 18 Design E n gin e e rin g D e p a r tm e n t.

19 I have held po s ition s of E n gin e er , A s sistan t a0 E n gin e e r, A e s ocia te A s sictant E n gin e e r , Design 01

~

Engineer, and S u p e r vis in g Design E n gin e e r.

22 Ihave been at Duke Power since June of '7 2, 23 f o ll o win g my g r aduatio n f rom the U nive r s it y of 94 Tennessee where I received a E ach elor of Science 25 Degree in C i v il E n gine e r in g.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

Tuchmen, Snow, G reen - Direct 21 1 I am a Pr of e r elonal E n gin e e r in the State 2 of North C a r olin a, lic en s ed in N orth C a r oli n a. I am 3 p r e s e ntly P r e sid en t-Ele c t of the North C a r olin a 4 Society of Civil En gine e r s.

5 Q C on g r atulatio n s.

. 6 h1 R . G Ii E E N : Thank you.

7 Q D e s c rib e your dutie s.

8 hi R . GRE EN: Supervising a group of 9 engineers responsible for the 'analy sis and design of 10 several building s and structures at C at awba , as w ell 11 as various a s s ignm e nt s that are bad creek pump 12 storage f a cilitie s.

(,

13 Q What b uildin g s do those include at C a ta wb a  ?

14 hi R . GREEN: A uxilia ry b uildin g s , spent 15 fuel pool, new fuel build in g , outside doghouses, 16 die s el generator b ui ldin g s .

17 Green, I b e li e v e Counsel etipulated Q M r.

18 that you participated in responding to several 19 Interrogatories, and R e que s t s for dis c o ver y requests, 90 Production cerved on Duke by Palmetto with respect 21 to our Contention 16 ?

22 MR. GREEN: Yes, sir.

23 let me show Q /. s I did with your c olle a gue s, 24 you Page Five of the October 18 document that is a 25 company document and ask you to examine the text of EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

Tuckman. Snow. Green - Direct 22 1 the C ontention reproduced th e r e..

2 You p r e viou sly are f amiliar with that 3 C onte ntion ?

4 MR. GR EEN: Yes, sir.

5 Q G entle m e n, M r. Green, since we have thr e e

. 6 p e o ple and we a r e' taping this D e po sition, l'f th'e' 7 qu e s ti on is not d i r e' e t e d s p e cific ally at you and you 8 want to com m e nt, please preface your comments with 9 your name.

10 MR. MCGARRY: For c on sis te nc y's 11 sake, you asked the previous Witne s s e s if 12 they had provided a f fid a vit s in R es pons e 13 to the Interrogatories; and we w oul d stipu-14 late that Mr. Green p r o vid e d an af fid a vit 15 with respect to the Int e r ro ga to rie s , the 16 fi r s t set of Inte rr o gato rie s, - no t the f ollo w 17 up set of Int e r r o g at o rie s dated October 18, 18 1982.

19 IV. R . GUILD: Thank you, N r. McGarr y.

20 21 GUILD:

BY MR.

22 O G e ntlem e n , P e. l m ett o I.111 a n c e is inte re s t ed 23 in the abilit y of Duke Power to accure it can s a f ely 24 store spent fuels fram not only the C t a vc b a pla nt but 25 f rom its other o pe r atin g f a cilitie s at C at awba.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA d

-,-n-y

Tuckman, Snow, Green - Direct 23 1 C oun s el has l'n e t r u c t e d you to not respond 2 to an e a rlie r qu e s tio n of min e c onc e r nin g the plan 3 for which the fuel storage f a cility a nd a s e c ciate d 4 procedures are designed.

5 I would like to ask you if you could tell me

. 6 what the design a'a su m ption s are as you understand 7 which are the bases for the design and procedures 8 for storage of non-Catawba fuele at the C a t awb a spent 9 fuel pools.

10 MR. SNOW: Those a s sum ption s are li s t e d 11 in the FSAR S e c tio n 9.1 12 Q Now, is it clear, kr. Snow, that those i

13 a s sum ptions are not the same as were lis t e d in the 14 p r e limin a r y safety analysis for the s tatio n FS A R ~?

15 MR. SNOW: There are a d ditio na l a s sum pti ons 16 in the FSAR.

17 Q If you can, sir, would you or the other 18 g e ntle m en, as appropriate, refer to that s e c tio n of 19 the FSAR 9.1?

20 Do you hrve a reference. 'M r . Snow, for 21 the a e r u m ption, where they can be found in the FSAR  ?

22 M R. SNOW: I would have to state that the 23 whole s e c tio n is a p p l i c a. b l e as containing the 24 They are nume rou s.

a s s um ptio ns.

3 Q W ell, le t's start s o m e plac e, and how about EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SEnvlCE. CNARLOTTE. NORTH CAROUNA a

T u c k rn a n , Snow, G re en - Direct 24 1

you helping me understand what a s s u m p tion s u nd e rlin e 2 the f u el s to ra ge plans of the company at C a t a wb a .

3 MR. SNOW: Can you restate your que s tio n, 4 pleas e ?

5 Q L e t 's back up, if we can, and ree if we

. 6 can focus: Was the C a t a wb a fuel s to ra ge f a cility, s 7 spent fu el storage f a cility, originally designed to 8 store non-C atawba fu els ?

9 MR. SNOW: It w a 's' not.

10 Vl e were lo o ki n g for a document r e fle c tin g Q

11 the original design. Would that document be the 12 ISAR p r elimin a r y safety analysis report for the

\

13 s tation ?

14 14 R . SNOW: Yes.

15 Q Without holding you to it, and we can go to 16 the document if necessary; but what were the baeic 17 l d es ign a s s um ptions as contained in the original d esig a 18 f o i- the f a cility r e fle c t e d in the FSAR?

19 MR. M CG A RR Y: I would object to thi s 20 li n e of inquiry in that the initial design of f -

at Catawba is irrelevant to the present design j

L 22 '

of the Catawba spent fuel pool.

l 23

H o ve e v e r , 'I will not in s t r uc t the 24 W it ne s s e s not to answer the qu e r tio n.

25 EVELYN BERG &R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA I

T uckm an, Snow, Green - Direct 25

, 1- DY h' R . G UILD:

(

2 Q W ould you try to anrwer the qu e s tion ?

3 MR. SNOW: I d on't think I can; it would 4 take a great deal of effort to id e ntif y individual 5 points.

. 6 Y ou would have to do it on a lin e by line 7 basis.

8 Q L e t 's f o llow this way: As you stated, the 9 fi n a l safety analysis report t'h a t is submitted in 10 support of your a p pli c a ti o n for an operating lic en s e 11 for the C a t a% b a station r e fle c t s the current design 12 a s s um ption s for spent fuel storage at the f acility; yer ?

(

13 MR. SNOW: Yes.

14 Q A nd tho s e a s s um ption s include t 5t e storage 15 of n on - C a t a wba fuels ?

16 MR. SNOW: T h a t's correct.

17 Q My in te r e s t, gentlemen, i s in focusing on 18 the design dif f e re n c e s and th e differences in 19 a s sumption s that have been adopted between the two 20 designs r e fle c t e d by those documents; and the e p e cific 21 means b y whic h the A p pli c a nt intends to demonstrate 22 that it can safely secommodate those d iff e r e n t 23 a s s u m p t i o n s. .

I 24 Can you help direct my attention to the 25 e81 8n changes?

l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERylCE. CHARLOTTE. NORTM CAROUNA a

,w , , , , - - - - + - - - - -, --

7 Tuckman. Snow. G reen - Direct 26

. 1 MR. SNOW: The design changes would agai n 2 be nume rou s ; but they would be associated with 3 phases that id e ntif y h! c C u i r e. or Oconee fuel.

4 MR. MCG ARR Y: I would lik e to put 5 another ob s e rvation on the R ec o rd: First,

, 6 it is th e nature of an obj e c tion, a 7 c o nti nuin g obj e ction with respect to any 8 discussions of the original design spent 9 fuel pool. '

10 I will not continue to poee the 11 o bj e c tio n; it will r e m a in as a co ntinuin g 12 obj e c tion.

/

13 I think what my o b s e r va ti on is is as 14 f ollow s : I think what was of interest here 15 is the underlying a s s umption c ritic ality.

16 heat load and structural analysis, and 17 perhaps that should be the appropriate area.

18 of inquiry.

19 MR. GUILD: Thank you.

20 21 BY h! R . GUILD:

22 Q h* hat are th e most im p o rta nt changes in 23 a s s um ption s in your j u d g m e nt and, therefore, changes 24 in design from the original fuel pool de sign and 25 storage plans to the p re s e nt fuel pool design and EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMADILOTTE. NORTH CAROUNA

T uc kman, Snow, Green - Direct 27 1 s tor a g e plan?

\.  :

2 MR. MCGARRY: A g ai n, to be helpful, 3 it may be simple, k r. Snow, if any of the 4 three Witne s s e s have any ob s e rvation s with 5 respect to that inquiry. I think you should

. 6 r e s p o n d'.

7 MR. TUCKMAN: Although I'm not a 8 member of the Design En gin e e rin g Force, 9 but rather an o p e rit o r --

10 11 BY MR. G U I'L D :

12 Q .Y o u are Mr. Tuckman?

13 MR. TU CKM AN: I'm sorry. I see very 14 few changes in the actual design of the pool to 15 a ccommod ate other than C atawba 'fu el.

l 16 Q M r. Tuckman or other gentlemen, how does 17 the c a pa city of the fuel as originally designed compar e 18 to the capacity as now s truc tur ed ?

19 M R. SNOW: The capacity was increased.

20 Can you quantify the increase?

Q 21 M R. SNOW: I b elie ve there are now 1,418 22 storage lo c ati on s .

23 Q Does th at represent passage of 1,418 24 a s s e mblie s ?

i 25 MR. SNOW: Excu se me, if that is correct ,

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA a

. _ . . . _ _ m . _ . _ _ . _. _ .- , _,-m._ _

Tuckman, Snow, G reen -

Direct 28 1 yes, 9.1-4, S e e tio n 9 . 1. 2 . 2 . 2 , "F a cility De a c ription. "

's 2 Q That is per unit a s s e mbly, per unit ?

3 MR. SNOW: Yes, sir.

4 Q What was the original design capacity for 5 the pools?

. 6 M R, SNOW: In th e order of 600.

7 Q W ould you accept the original design was 8 662?

9 MR. GR EEN: T h a t' ' i s a p pr oxim a t ely right.

10 Q G entle m en, from a design engineering stand -

11 point, and I guess appropriately M r. G re en and Mr.

12 Snow, what is th e si gnific a n c e of more than d ou b lin g

(,

13 the design capacity of the pools?

14 MR. SNOW: An analysis was performed fox 15 the co olin g system that demonstrates the ability of 16 the c o oli n g system to accommodate the heat load.

17 Q I understand that, and we do want to talk 18 about that; but let's talk in te rm s of general 19 principles fir s t and then get to s p ecific s .

20 Can we ac ce pt that the increase in capacity ,

21 design c a p a c it y, represents.a si g ni fic a nt design 22 change in the f a cilit y ?

23 M R. SNOW: N o, s i r ; I would not characteri ze

' 24 '

it that way.

95 in eithe r Q What is the si g nific a nc e, EVELYN E ERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA o

., , . , , - - - - ,,-w- - - - c- - y

Tuckmon, Snow, Groon - Diroct 29 1 qualitative or quantitative terms, o f doublin g the i

2 capacity of the spent fuel storage f acility ?

3 MR. SNOW: It is a larger volum e.

4 Q What is the significance of that larger 5 v o lu m e, g e n tle m e n, to the ability of the company to

. 6 s af ely conduct storage a ctivitie s that it ceased to 7 conduct at the f acility ?

8 MR. SNOW: It has no s ignific an c e.

9 Q Do th e other g e n t l e'm e n agree with that t'

10 answer?

11 MR. T U CKM A N: I agree.

12 M R. GREEN: I agree, too. ,

(

13 Q Is the heat load to be expected at th e 14 f acility increased over its original design c a p a cit y ?

15 MR. SNOW: C a p ability d the c o olin g 16 s ys tem is such that it would accommodate the heat 17 load as evaluated.

18 I appreciate your position about th at, sir, Q

19 but let me ask the qu e s tion one more tim e: The 20 que s tion is, is the heat load increased as a r e sult 21 of the increased s tora ge capacity of the fa cility ?

22 MR. SNOW: T hat is an a s s umption 23 d e p end e nt--t h e re are a s s u m p tio n s for which that w oul

12 one-third of the caek. ,

( , ,

13 sirs, Q A ll right, .in' the v e r tic al center 14 " '

line of the cask?

15 MR. GR E EN: Yes, sir, 16 Q Is that a unif o rm c onfigu r a tion that covers '

17 the make and manu f a c tu r e r 's --a s long as we are ,

18 a talking about truck casks, for the lif tin g ' lu g mand the 19 location of that lif tin g lug ?

/

90

~

MR. GREEN: I'm not sure it is unif o rm, 91

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I' m not f a milia r with a ll the cacks.

go~ '

Q Do you know whether the casks t h a t' w e r e 23 id en tifie d in response to Ea r lie r qu e s tio ning, t'h e ,

24

~

c onfig t ratio n i s th e same as you have just ~deceribed1 25 MR. GREEN: C o uld you repeat that?

EVELYN BERGER Af SOCIATES. STENOTYPE ftEPORTING SERylCE. CMARLOTTE. NORTH CAROUNA o

. - - - - , - - - - 4 - - - - - . . ~ , - . # , - ,m , ,-,e- ,- _ , - - , - -

T uc hmar , Snow, G re en - Direct 84

1 Q Sure, for the cacks that are set out in 2 c a. r li e r answere in the A p ril letter, are the lif ting

, 3 lu g e and general c o nfigu r a tion s of those casks, the 4 truck ca sks now as you have de s c rib e d the m ?

5 MR. GREEN: Yes, sir.

s

/ I

? .

g 4 j' , - ' 6 Q Just to' give a c ompa r ative response for a

7. rail cask where would th e lif tin g lu g be?

8 MR. GREEN: Same general p o s itio n.

9- Q Is this an ac curats' r e pr e s entation of a rai 10- cash as shown in that 8.1.2-4 figu r e ?

' ~

j 11 MR. G R EE N :- I cannot remember if this is

, 12 a r epre s entation of a rail cask or truck cask. It is 13 the largest one or the one that would be th e most

, 14 ; c ritic al for the cask drop i n v e s t i g a. ti o n .

15 Q Would you agree that the largest cask woul d 16 be a rail cask?

17 MR. GREEN: I would say s o.

18 Q How many a s s emblie s does a r ail cask hold  ?

19 MR. GREEN: I don't know.

l 20- Q Does it hold more than one?

21 MR. GREEN: I don't know.

2:! Q Are there casks that are s m a ll e r than the 23 cachs th at are reprecented on fi gu r e 9.1.2-4 th at (d

24 w ould be ernployed at Catawba station ?

! - 25 Iv. R . GREEN: A gain, I don't know whic h

(

r

2. evrun a enorR AssociArts. sTENOTTPE REPORTING SERVICE. CHAR OTTE. NORTH CAROUNA

Tuckmno, Snow, G roea - D1roct 85

.. I cask would be e mplo y e d at Cctawba Nu cic e r Station 2

at this tin.e. but yes, there are esshe emaller than 3

the one r epr e s ented in that figu r e.

4 Q Cen you give me a general comparative 5

reference if a cask shown in the fi gu r e that has been

. 6

, r epre s ented as the largest cash is shown to be eight 7

f e et wide by seventeen. feet t a ll, what would the 8

a p p r o xima t e dim en s io n s be of the s m all e r cask?

8 M R. GREEN: I c o n'i d n ' t tell you that.

10 Q Do you have an e s tim a t e, es a p p r o xim a tion ?

11 g[ht . GR EEN: I r e a lly d o n ' t, it ranges, 12

,. like I said, there a r 'e s eve ral ca shs.

s 13 Q A ll right, sir; M r. Tuckman, back to the 14 12 5 ton crane.

15 MR. T U CKM AN: Okay, the cask is lif ted 16 and put into the area shown as the DECON Area. It I7 is right in the center of the upper icit d r awin g,, o n tho I8 right side.

18 O The 125 ton crane, would you describe its 20 c o nfi gu r atio n and path?

21 M R. TU CKM AN: If you look at FSAR Figur e

  • 2

~

911- 2, it shows you th e main cack h a nd lin g crane.

23 Q I see, that identified as cark h a nd li n g crar.e.

94 and it shows cap., c a p a city , 125 tons?

25 MR. TUCKMAN: Richt.

evrov~ ... ora nociares. sr ~oryce irearm se vice, c==torre. .xmrw camou .

Tuckmen, Snow, Groon - Direct 86

- 1 Q The main branch of that crane travels in 2 an e a s t-w e s t direction, which the t r olle y is in the 3 north-south di r e c tio n ?

I 4 The bridge are those, the r a il s on which 5 the t r olle y travels (in dic atin g) ?

6 MR.

T li C K M A N : Yes, it is the r ails on 7 which it travels.

8 with reference to the Q A ll right, fi g u r e that 9 appears in the left top f i g u r e' ' w h i c h appears at 10 9.1.1-1, wha t. is the range of m ove m e nt of the load 11 supported b[the 125 ton crane?

12 On Figure 9.1.2-3 it show

,. MR. TU CKM AN: s 4 '

13 the e a s t-we s t stop of the c a s k ha ndlin g crane 14 (indic a tin g) there.

15 I will add a c o r r e c tio n to this d r awin g.

16 over further in the west The r ail s a c tu ally do not, II dir e c tio n where the stop is in s talle d--

18 The r ails extend over the Spent Fuel Storag e Q

19 Racks and the Spent Fuel Pool?

i 90 Yes, and the stop will be M R. TU CKM AN:

21 in s t alle d where shown.

22 Why were the r a il s extended beyond the Q

23 li mi t shown in that figure ?

(

- 24 MR. GREEN: Mike G r e e n; it was put in 25 there for c o n s truc tion purposes and for in s t alla tion EVELTN DE RGE R ASSOCIATE S, STENOTYPE REPOsrTaNG EERVICE. CHARLOTTE. NORTH CAROUMA e

-+, , -

, n , ~ - , - . . _ , . , - - - -

Tuckmnn, Snow, Grosa - Direct 87 1 of the gpent fuel racks and to the pool.

2 I might add that those r ail s are up there, 3 but they cannot be accessed by the 125 ton, cask 4 h an d lin g crane af te r the stops are in c t alle d.

5 Q D e s c rib e please th e stop s that you are

. 6 referring to that 'e i t h e r have been added or will be 7 added to those rails.

8 MR. GREEN: The stops are f ab ric ate d out 9 of carbon steel, woven up s e 'c',t i o n s .

10 Q How are the y in s talled on th e rails ?

11 KfR. GR EE N: They r. r e either bolted to th e 12 r a il s or they are welded to it, I don't know at this 13 ti m e.

14 Q Are they in s t all e d at this time ?

15 MR. GREEN: Yes, sir.

16 MR. .T U C K M A N : T h ey a r e in stalled at the 17 far end of the r ail now, and they will be moved for-18 ward and b olt e d in place.

19 Q So the stops in place now will a ll o w the 20 ,125 ton crane to roll over the top of the fuel pool?

. 21 MR. GREEN: Yes, as it is now in s t alle d; 22 it will be m ove d back to the lo c a tio n shown in Figure '

23 9.I-2.3.

24 Q What is the north-south range of m ove me nt 3 of the 125 ton crane?

EVELYN S ERG ER ASSOCIATES, STENOTYPE REPORTING SERVICE, CHARLOTTE. NORTH CAROUNA

Tuckman, Snow, Groen - Direct 88 1 MR. TU C KM AN: If you lo o k on Figure 2 9.1.1-1, again, the fir s t fi g u r e , the upper lef t shows 3 th e rail for that crane.

4 They are e s s entially to the north-s outh 5 walls of the New Fuel B u lldin g c olum n, Line 48 to

. 6 51.

7 Q The r ail s and stops as now in s ta lle d then 8 would allow the 125 ton crane and its load to range 9 all above the Spent Fuel P o o l' ', a s w ell as the bay, the 10 r ec eivin g bay, and the D e c on ta min a tion Area?

11 }dh. TUCKMAN: Yes, what you pointed to 12 is not the Spent Fuel Pool; it is New Fuel Storage.

(

13 Q Where in this c onfigu r ation ?

14 (Mr. Tuckman indicated the 15 desired inf or mation to Mr. Guild. )

16 17 BY h2 R . GUILD:

~~:

18 Q On this side, all right. The cask is raise i 19 then in the bay? ,

20 MR. TU CKM AN: The cask is raised in the 21 bay and placed in the Decontamination Area, which is 22 the fir s t opening that you see.

23 Q Now how m m.n y personnel and which 24 p e r s o nn el th at you have id e n tifie d before would be 25 involved in this lift and the o p e r ation s you have

.m,~ ...an a .ssociates. sr=~orvre asromaa semer. c=a;ons ao m c"ou"*

T u c km an, Snow, Groon - Direct 89 1 d e s c rib e d so f ar ?

2 M R. TU CKM AN: O pe ration s personnel 3 would do that.

4 Q Id e ntif y who those were.

5 MR. TUCKMAN: Nuclear E qu i p rn e n t

. 6 O p e ra t o r s would operate the cask h a n dlin g crane to 7 move th e cask from th e truck to the Decontamination 8 A r e a.

9 Q Who is r e s p o n s i b l e ',f o r rigging the crane 10 on the cask?

11 dh . TUCKMAN: The O p e r a tio n s personnel.

12 Q Who of that--

^

13 M R. TU CKM AN: The people that actually 14 do the wo rk ar A the N u c l e a. r Equipment O p e r'a t o r s unde r 15 the direction of the Fuel H a ndlin g Supervisor.

16 Q One person is rigging the cask?

j 17 MR. TUCKMAN: No, two.

2 18 Q What work does each of them perf o rm ?

i l

19 MR. TU CKM AN: It would most likely be i

20 the Nuclea r E qu ipm e nt Operator and the M aint enanc e 21 and person to af fix the c lin g to the cask handle, 22 there would be another person o p e r atin g the crane.

23 Q With the supervisor observing?

24 MR. TU C KM AN: Yes.

25 The cask is lif t e d fir s t and then moved ?

Q EVELYN BERGER ASSOCIATES STEh0 TYPE REPORTING SENysCE CHARLOTTE NORTN CAROUNA

T uckmca, Snow, Groon - Diroct go 1 M R. TUrKMAN: To the Decontamination 2 A r e a.

3 Q And lowe r ed into the D e c onta min a tio n Pit?

4 M R. TU CKM A N: Yee.

5 Q W ha* happens th e n ?

. 6 M R. T U.C K M A N : Once it is in the Decon.

7 tamination Pit, th e cask is fill e d with wa t e r.

8 Q The cask is filled with wa te r ?

9 MR. TUCKMAN: Y'ei e . casks are shipped 10 dry with H e liu m atm o s phe r e. The cask vent is 11 connected to the Spent Fuel Pool ventilation s y s t e m.

12 The fill line f rom out of the S p e nt Fuel i

13 c o o lin g or d emin er aliz ed water is connected to the 14 cask. ,

15 W at e r dis pla c e s the H e lium which goes out 16 to the Spent Fuel Po ol ventilation system until the 17 cask is fill e d with wat e r.

18 Q A ll right, stopping there and going back, 19 how is the c a s k fille d with water ?

20 MR. 'T U C KM A N: A hose would run from the 21 S p ent Fuel c o o lin g or d e mi n e r a li z e d water to the cask .

22 Q What is the connection on the caek with the 23 .lh o s e s ?

24 N. R . TU CKM AN: Hose c o n n e c t i o r. .

25 Q If you would describe it.

e mv~ .... . ..soci.v s. sra orre . .oni~a sc.vics. c,. ym. om c..ou~ s

Tuchman, Snow, Groon -

Diroct 91

- 1 MR. T U C K 2/. A N : It has been a long time

(.,

2 since I' v e looked at it.

3 Q To t h.e beet of your knowledge.

4 MR. TU CKM AN: More than likely with 5 disconnect fittin g s .

. 6 Q What is a disconnect fittin g ?

7 M R. T UCKM AN: You plug it in.

8 Q Snap fit tin g ?

9 MR. TU C KM AN: S'o m e t h i n g like that.

10 Q What kind of hose?

11 hl'E. TUCKM AN: Rubbe r ho s e.

12 Q Garden hose?

f 13 MR. T U CKM A N: Ho p ef ully :a little better 14 grade, but s o m e thin g s imila r .

15 Q Snap fit tin g, do you need to open a valve ?

16 M R. TUCKMAN: Yes.

17 Q Is the valve accessible on the outside of

~:.

18 th e cask?

19 M R. TU CKM AN: Yes, it is.

20 Q No other equipment or features of th e caek 21 have to be handled in order to snap the hose onto the 22 valve ? '

23 h. R . T U C K M A N : No.

6

\ 24 Q What kind of valve is opened?

25 M R. TU CKM AN: It is a manual valve.

emv~ .a cia .ssociaras. sta~orres asaoarmo semer. cua yorra. ~om c4=ou~a

T u c k m r. r. . Snow. G rann - DLroct 92

., 1 Q Gate valv e ?

2 MR. TUCKMAN: I don't know the s pe cific 3 valve in use on that cask.

4 Q Does it require a wrench to do it ?

5 ,g R , TU CKMAN: I can't answer that one.

6 g po, i t'.v a r y from cask to cask?

7 MR. T UC KM AN: I would imagine it would, 8 but I do n' t recall.

9 Q A nd the other end 'of the hose is connected 10 to what ?

.- p.. .?.;

11 gg. TUCKMAN: T o the Spent Fuel Pool 12 v e ntilatio n --I' m sorry--this hose.

13 Q The water hose?

14 MR. T U C KM AN: Eith e r the Spent Fuel 15 Po'l c o olin g s y s te m or to the 'd e min e r a li z e d wate r 16 c onn e c tio n. , ,. __

17 Q W ould it draw w a.t e r that would circulate I8 through the S p ent Fuel Pool?

19 MR. TU C KM AN: It is water on the dis char ge 20 of the Spent Fuel Pool pump.

21 Q It has been filt e r e d down there ?

22 Yes.

MR. TU CKM AN:

23 Q Is there a s p e c'i fi c valve or water source i

24 th at is located, and where is it loc ated that you woul d 25 m ak e this c onn e ction to ?

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOME. NORTH CAmouMA o

Tuckman, Snow, Green ' - Direct 93 1 MR. TU CKM AN: Both the d e min e r ali z e d an,i 2 Spent Fuel c o o li n g water have taps near the 3 D e c o nta mina tie n Pit.

4 It you look at Figure 912-2--

5 Q Yes.

. 6 MR. T U.C K M A N : Both c onn e c tion s are 7 roughly between the lef thand side of the drawing 8 b etwe en c o l.u m n.s TT and SS on the upper p a r t. o f. t h e 9 d r e. w i n g . ',

10 Q Does th at indicate it is valve pit ?

11 h[R . TU CKM A N: They are not in a pit, no.

12 Q They ar e not shown on the drawing?

(.'

13 MR. TU CKM AN: I see; they are b a s i c a lly 14 here (in di c a tin g) . The S p e nt Fuel c o o' in g lin e is her a l

15 and the d e min e raliz ed wate r is here (in di c a tin g ) .

16 Then another hose is connected where?

Q 17 MR. T U C KM AN: Another hose is connected T.

18 from the cask vent to t h e' Spent Fuel Pool ventilation 19 s y s te m.

20 The Spent Fuel Pool ventilation s y s t e m.

Q 21 that is an air syetem?

22 M R .. TUCKMAN: Yes.

23 Q As opposed to a liquid systom?

k 94 MR. TU CKM AN: Yes, a v e n til a ti o n system .

25 Q Where is the Spent Fuel Pool cask vent aveten ermon = associare s. srs=OTvre REPORTING sE RylCE. CMARLOTTE NORTM CAROUNA

Tuckman, Snow, G re en - Direct 94 1 located t ypic ally ?

k,.

2 MR. TU CKMAN: It is on the same drawing 3 on Figure 912-2 on the bottom of the d r s. vri n g in this 4 area (in di c a tin g) .

5 Q I'm talking about the cask, M r. T u c $c m a n ,

. 6 the cask, it s elf.

7 MR. T UCKM AN: It is on the hea'd of the 8 cask.

9 Q Y ou mean at the to'.p of the cask in the 10 raised p o s ition ?

11 ' 's M . TUCKMAN: Yes.

12 ,Q How is the vent c o nn e c tion made ?

?s 13 M R. TUCKMAN: In a simila r manner as 14 the water c onn e c tion.

15 Q It is a snap fitting ?

16 MR. TUCKMAN: I think so.

17 Q Do you know what kind of valve is connecte d 7

18 to it?

19 M R. T U CKM AN: N o.

20 Q Is it accessible on the outside of the cask '

21 T UCKM AN: Yes.

ht R .

22 Q A nd a gain, you started to say the other 23 end of that hose is connec'ted--

' 24 MR. TU CKM AN: To the Spent Fu el Pool 25 ventilation system which is on Figure 9 .1. 2 - 2 in the emr= .e....

.. soc..res. sr.~orres asro vm . =viec. ca.3em. =om ca ou a

T u c kman, Snow. G reen - D!roct 95 1 low e r left corner.

2 There is a c o nn e c tio n to the ventilation 3 c ys tem.

4 Q Wat e r displaces th e H elium ?

5 .MR. TUCKMAN: Yes.

. 6 Q The H ailum is processed through the cool 7 vent system?

8 M R. T U C KM A N: Yes.

9 Q Filt e r e d and d i s c h a'r g e d to th e atmos phere ?

10 MR. T U CKM AN: Yes.

11 Q dikat happens when the cask is fille d th en ?

12 M R. TU CKM AN: Once the cask is fill e d 13 we unbolt th e head of the cask.

14 Q Are the c on n e c tio n s still made; the hose 15 c on n e c ti o n s still in plac e ?

16 MR. T UCKM AN: No, they are disconnected 17 l before we unbolted it.

l 18 Q You disconnected and clo s e d the valv e ?

l.

l 19 and unbolt MR. T U CKM AN: That's correct, 20 the head from the cask.

i 21 Q Now where is the cask and what kind of 1

  • 22 l e nvir o nm e nt is the cask at the point where the head l

23 l

b olt s are unbolted?

24 l MR. TU CKMAN: In the De c ont amination 25 P it in a v e r tic al p o s itio n still connected to the crane .

1 . _ . . . . . . . . . . , . . . . . - . . . - . . . - . . _ . - - . _

I _ _ . - . . _ - . ._. . . -- . . , _ _ . - --

Tuckman, Snow, G reen - Direct 96 l

1 Q A ll right, is there wat er in the D e c o nt a mi-2 n a ti o n Pit ?

3 M R. T UC KM AN: N o.

4 Q How many bolts are there on t h e' ' head of 5 the cask?

. 6 MR. TO CKMAN: I don't know.

7 O What kind of equipment is used to unbolt 8 those bolt s ?

9 MR. TU C KM AN: N.'rench.

10 Q . Standard wrench?

11 hiR. T U CKM AN: S o m e what diff e r e n t than 12 standard.

^l, 13 Q Is it a unique decign for this purpose?

14 M R. TUCKMAN: Yes, it is.

15 Q C an you d e s c rib e it?

16 ER. TUCKM AN: I r cally co u ld n' t now.

17 Q Is it a manual wrench or p o w e r e d, . w r ,~

ench?

18 M R. TU CKM AN: I can't answer that for l 19 sure.

20 MR. GUILD: Any other g entle m en, 21 . . .

please volunteer.

22 #

MR. GREEN: I don't know, .I .r e a lly 23 d o n ' t.

f 24 MR. SNOW:

(Shook his head n e g a tiv el y.)

l 25

...u ...... ...oei.re.. .r.aervre aero riaa . avic . caa wire. ao m caaoua^

Tuckman, Snow, G reon - Dir ec t 97

, 1 Q What type b olt s are we t alkin g ab o u t, . s m al:

2 b olt s, large bolts; talking about five, talking about 3 twenty ?

4 G iv e me an approximation if you don't 5 know the s p e c ifi c answer.

. 6 MR. TUCKMAN: There is a lot, I,would 7 guess more than a dozen; you are talking about 8 s ub s tantial bolting.

9 Q More than an i n c h 'd,n diame t e r ?

10 MR. TUCKMAN: I c ould n' t answer that.

11 Q WTr o performs the unbolting ?

12 M R. T U CKM AN: M aint e nan c e personnel.

.,I 13 Q The one, th e mechanic w hi c h you indicated 14 e arli e r ?

15 MR. T U CKM AN: Yes.

16 Q Is the mechanic shielded f rom the cask?

17 M R. T U CKM AN: N o.

18 Q How does the mechanic p hy s i c a lly r emove 19 the bolt s ?

20 MR. TU CKMAN: There is a grating he 21 s tand s on which is a p p r o xima t ely the height of the 22 cask head. '

23 Q Adjacent to i t ?

j

- 24 MR. TU CKM AN: Surrounding it, and the 25 bolt is r e mo ve d.

. m . ...... ........... m ~ .. .. - ~. .. -

.c~. 7 m ..~ ~ c - ~.

Tuckman, Snow, Greon - Direct 98 1 Q Where are the bolts placed when they are 2 removed?

3 MR. TUCKMAN: I don't know. Our pro-4 cedure, I may add, the procedure for each cask is 5 s om ewhat diff e r e nt, s p e c ifi c a lly on bolting patterns 6 and types of tools.to be used.

, 7 It is as much as, I don't know which cask I .

8 we would use. I'm n ot f amilia r with the d e t ail s .

9 Q Is it fair to say a t' M c Guir e th e r e are 10 procedures within and in pince for each cask used at 11 that f a c ilityh 12 MR. T U CKMA N: Yes.

('

13 Q 'A n d they d e t ail the s p e cific procedures?

'14 MR. TU CKM AN: That's correct.

15 Q And they are similar to the procedures in 16 this respect that would be finally in place at Catawba  ?

17 MR. TUCKMAN: I expect th a t 's correct.

T.

18 Q Now describe th e job r e quir e m ent s, 19 qualific a tion s , of the individual or individuals who 20 will pe r f o r m the f un c tio n s you have just described, 21 r em oving the bolts.

22 MR. TUCKMAN: I can't tell you the

~ ~

23 qu alific a tio n s of that p a r ticula r ~ individual.

( 24 Q Have those been e s tablis he d ?

25 MR. TU CKMAN: Not at Catawba, I'm sure EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROUNA

Tuckman, Snow, Green - Direct 99 I they are at McGuire.

2 O You are just not f amilia r enough?

3 MR. TUCKMAN: No.

4 O Will there be special training?

5 MR. T U CKM A N: Yes.

. 6 Q Do you'know what that special training will 7 consist of?

8 MR. TU CKMA N: Just training of the task 9 to be done. '

10 Q Is there any curricula, text, written 11 t r ainin g m at e rials for this task?

12 MR TL CKM A N: Do they exist now?

f s

13 Q Yes.

14 MR. TU CKM AN: Not at C a ta wb a.

15 Q Are there training materials at M cGuir e 16 that will r e fle c t what t r ainin g m ate rials will be used 17 at C atawb a ?

18 MR. TU CKM AN: I would i ma gin e s o, b ut I' m 19 not f a milia r with it.

20 Q /.11 right, the b olt s are ph y s ic ally removed  ?

21 ( Wh e r eu p o n, Mr. Tu ckman nodded 22 his head af firma tively. )

23 O And next?

24 hi R , TU CKM AN: Next the cask is lif t e d M again and placed in a shallow end of the cask area.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA e

-~

Tuckman, Snow, Green - Direct 100 1

, 1 Look on Figure 912-2, and you will see that the thin g '

(

2 says, " . . . fl a t f orm in the lower half of the area."

3 (Indicating).

4 O The cask is placed in that location ? It ha<1 5

f o rm e rly been in the D e conta minatio n A rea ?

6 MR. T U CKMAN: T h a t 's correct.

7 Q Lif t ed and set down again on that pla tf orm ?

8 MR. T U C K h1 A N : T h at's correct.

9 Q M oved in an easterky dir e c tion--no, 10 wes te rly dir ec tion ?

11 MR. T U C K h1 A N : Not we s t e rly di r e c ti on.

12 North is at the bottom of this fi gu r e, yes.

13 Q What is between the D e c o n ta min a tio n Area 14 and.the platfo rm ?

15 h: R , TUCKMAN: A w a 11, 16 Q W ould you describe it ?

17 ht R . TE CKM AN: It is made out of concrete ,

18 it is about six feet.

19 MR. GR EEN: That is a four foot, reinforc ed 20 concrete wall s e pa r atin g the DECON A r e a. f rom the 21 Cask Pit Area.

99

~~

Q I direct your a t t e n ti o n to Figure 9.1.2-4; 23 is thia the w a ll that would be to the left of the Caek 04

~

Area in that dia gr am ?

25 MR. TE CKM A N: Yes.

EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE, CHARLOTTE. NORTM CAROUNA

Tuckman, Snow, G roon - Direct 101 1 Q It is lowe red onto the pla tf o rm ?

2 MR. TU CKM A N: At this point the head is 3 removed f rom the caek.

4 O Is it under wate r ?

5 MR. T UC KM AN: Yes.

. 6 Q What is' the depth of the water in the area 7 where the cask is lowe r e d ?

8 MR. TU CKM AN: The elevation of the plat-9 form is 583. '

10 N R. GREEN: The a p p r o xim a t e depth of the 11 water is 15 ~~ feet at the upper pla tf o rm level.

12 Q How much water then is above the top of 13 the cask without the cask lid removed, before the 14 cask lid is r e mo v e d, a pp r oxima t ely ?

15 MR. TU CKM AN: Depends on the s p e c ific 16 cask. -

17 Q We show a cask drop elevation at seven 18 f e et; wo ul d that protrude out of the water if that wer e, 19 in fact, the true dimen sions ?

20 MR. TU CKM AN: Yes.

21 MR. GREEN: The cask that is depicted in 22 the cask drop ele vatio n, as I said, is the maximum "

23 dim e n sio n, the ma ximu m si=e of any c a's k- t h a t we 24 could find or id e n tif y at that tim e.

25 It may be, indeed, the cask that would be EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

Tuckman, Snow, Green - Direct 102 1 used for cask transfers.

2 Q If you used the cask shown in that cask 3 group ele v a tio n, it would be unshielded if it were 4 lowered onto that platf orm ?

5 MR. T L C K h: A N : Yes, sir.

. 6 Q So yo u 'would want to use a s m alle r cask 7 or lower platf o r m or higher wate r ?

8 MR. TUCKMAN: W e ll, the water in the 9 cask, it s e lf, would shield i t .' - It wouldn't need to be 10 directly over the top of that cask.

11 Q So you are a s suming a s m a ll e r cask and I 12 may have m i. s s e.d an e a r li e r answer, but how much

( '

13 water is intended to be above the c a s k lid before the 14 lid is r emo ved ?

15 h. R . TU CKMAN: I don't b e li e v e th e r e is 16 a s pe cific ation on it.

17 Q Can you e s tim at e how much will be above 18 the lid ?

19 hi R . TU CKM AN: A foot or so of water.

20 Q That is above the to p of the li d before the 21 lid is r emoved ?

22 h: R . TU CKM AN: Yes. -

23 Q II o w t hi c k ie the lid a pp roximat ely ,

f- 24 ty pic ally ?

25 MR. GREEN: I d o n' t kno w.

EVELYN SERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

T uc km a n, Snow, Green - Direct 103 1 Q A foot or more?

2 k. R . GREEN: I couldn't tell you.

3 Q How are the bolt s removed f rom the lid 4 before the cask is moved into the platf o r m ?

5 U. R . TU CKM AN: I'm almost certain they

. 6 are--

7 Q Not c e r tain ?

8 MR. TUCKM AN: Not 100 percent c e r tain.

9 Q If they are not, how are the b olt s removed 10 once the cask has been lowered onto th e pla tf o r m ?

11 g'R . TU CKM AN: If they were not removed 12 they would come off with the head, pic k up th e head

(

13 and bolts would come with them.

14 Q The b olt s are free if they are still on th e 15 cask?

16

.MR. TU CKM AN: They are not bolte d., I 17 r eally can't remember the procedure.

18 Q P h y sically then, how is the lid removed 19 f r om the cask on the platf or m ?

20 MR. TU CKM AN: The lif tin g fixtu r e irom 21 the cask is disconnected.

22 Q F rom the lif tin g lugs?

23 In R . T U CKN AN: Yes.

24 l Q A ll right.

25 F. R . TU CKM AN: We have to disconnect the EVELYN BERGER ASSOCIATES. STENOTYPE PEPORTING SERYlCE. CNAECTTE. peORTM CAauOuMA

Tuckman, Snow, Green - Direct 104 i

. I lif ting fixtu r e to put the extended lif tin g fi xtu r e , to

(>

2 move the cask to the deep end.

3 The head is grasped by th e fuel crane and 4 li f t e d off.

5 Q The fuel crane is the same 125 ton crane

. 6 we were speaking'of?

7 MR. TU CKM AN: Yes, I think the y used the 8 a uxilia r y hoist on that; that is a ten ton crane.

9 Q The a u xili a r y h o i s t' ' i s fixe d to the head?

10 MR. TU CKM AN: Yes, it has a separate 11 bridge and t r oll e y that extends to the Spent Fuel Pool 12 handling crane, s

13 Q Show me where this erane is that you are 14 r ef e rrin g to.

15 M R. TU CK M AN: It hangs off the bottom of 16 the 125 ton crane on Figure 9.23, but it is not shown ,

17 It is referred to as what a gain ?

Q 18 MR. T U CKMAN: Ten ton, au xilia r y hoist.

19 Q A uxilia r y hois t ?

20 MR. TU CKM AN: (The Witne s s nodded his 21 head a f fir ma tively. )

22 And is its range the same as the range we Q

23 have d e a c rib e d e a r lie r for the 12 5 t o n crane now and 94 to be used when the f acility is operational?

25 ER. GREEN: It has a somewhat dif f e r ent EVELYN BERGER ASSOC 8ATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

1 T uc kman, Snow, G reen - Direct 105 1 range on .1.1 - 1 in the upper icithand corner; there is 2 a shaded area which depicts the range of th e main 3 hook, your fiv e ton capacity hook and ten ton auxiliar y 4 center lin e that we are speaking o f.

5 As you can see on the east end it can

. 6 extend over the New Fuel Storage Area. On the weat 7 end it has t 'h e s imila r range of t h e' main hook.

8 Q What is the range for this a uxilia r y hoist 9 over the Spent Fuel Pool? '

10 MR. GREEN: It cannot reach over the 11 S pent Fuel Pool.

12 Q Can it reach over there now ?

(~ 13 MR. GR EE N: Now it can; in o pe r a tion it 14 c ould n ' t bec~ause the stops prohibit m o vin g of that.

15 Q Same stops you m e ntion e d ea rlie r ?

16 MR. GREEN: Yes, as I said, it is connected 17 to the main 125 ton crane a s s embly.

18 Q Do I understand th at the range of the ten 19 ton hoist is li mit e d r. n d s m a lle r ?

20 MR. GREEN: Yes, on the Spent Fuel Pool 21 that is true.

~

22 Q Why is it greater on the other end thouEh.

23 if gg 13 7 24 M R. GR EEN: I don't know if I follow you.

25 Q I m ean is it an accurate statement that the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROLINA

T u c km an, Snow, G reen - Direct 106

,. I range of the ten ton hoist is limited to the range of 2 the one hundred twenty-five ton holot f rom whi c h . it --

3 MR. GREEN: The range of the ten ton 4 hoist is limited by the same stops that li mi t the 5 one hundred twenty-five ton hoist.

6 The exact dim en sion s of the center line of 7 the au xili a r y hoist are not id e n ti c a l to the dime n sio n r s s

8 of the main hoist.

9 Q Can the auxiliary hoist extend beyond the 10 range of the 125 ton hoist?

11 h: R . GREEN: Yes.

12 Q Ple a s e help m e unde r s tand, what is that i

13 I' m tr yin g to focu s on?

14 MR. G RE EN: It cannot get over the Spent 15 Fuel Pool level, 16 Q On the east side, the side over the new 17 fuel it can go fu rthe r ?

18 h1 R . GREEN: Yes, sir; that is the hoist 19-ured to load new fuel.

l 20

( Q Just as g e om etr y, how is the range, the 21 larger range possible over the new fuel but not over 22 the spent fu el ?

23

h. R . GR EEN: The m ain, 125 ton a c r embly i

94

~

has a larger d ru m, la r g e r windings, everything els e 25 f r om a stop to the center lin e of a m ain, it ta ke s up EVELYN SERGER ASSOCIATES. STEh0 TYPE REPORTING SERVICE CHARLOTTE. NORTM CAROUNA

Tuckman, Snow, G reen - Direct 107 1 more epace than it would for a 10 ton boirt.

2 You can get closer to your end point, your 3 stop, w it h a s m a ll e r h o l e; t .

4 O The cask 11 d then is r emo ved with the 5 a uxili a r y hois t ?

. 6 M R. TU CKM AN: Yes.

7 Q W he re is it put?

8 MR. T U CKM AN: I don't think we have--do 9 we have a designated s to r a g ee pot for it?

10 N R. GREEN: It is not shown.

11 1.[R . T U CKM AN: I'm not sure what the 12 designated storage location for that is.

(

13 Q What are the po s sibilitie s ?

14 ER. TUCKMAN: Back on the s la b north of 15 the DECON Area on Figure 9.2-2 (indicating).

16 Q Yes. Now, at this point is the cask on th e 17 platform that is indicated as " platf o rm" ?

18 MR. TU CKMAN: Yes.

19 Q What is th e cask area that is just above 20 thr.t on this figu r e ?

21 MR. TU CKM AN: That is a s olid platf o rm.

22 T hi s is a shallow depth and a deeper depth (indicatin d.

23 Q I see, I understand. All rig ht, sir, so it 24 is in the s h a llo w depth, whic h is in the lower of tho ne 25 two.

EVELYN SEPGER ASSOCIATES, STENOTTPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA

Tuchman, Snow, Green -

Direct 106

/

1 MR. T U CKM AN: The lower in the drawing.

2 the bottom of the d r a win g.

3 MR. GR EEN: That is 583 plus 6 elevation.

Q All right, 4

ths.t is where the cask sets?

5 MR. TU CKM A N: That's right.

, 6 Q We have the lid removed, then what?

7 MR. TUCKMAN: We attach the long lif tin g 8 fixtu r e to the cask.

9 Q That is what you 'c'a l l the extended li f tin g 10 fixture ? '

11 ?v. R . TUCKMAN: Yes.

12 Q What is its c o n fi g u r ation; describe it ?

13 MR. TU C KM AN: It is a s li c k, ve rtic al 14 spreaders.

15 Q A nd it extends further down th e cable ?

16 MR. GR E EN: It a llo w s a greater distance 17 between th e center lin e of the rr. a i n hook and the cash .

18 It is th e r eb y not putting as much of th e e a s ting cable 19 into the water.

20 MR. TU CKM AN: It ba eically allows you to 21 low e r the casks to a deeper depth without s u bm e rgin g 22 ,

t he crane into the fuel pool area.

23 Q T hen what?

24 MR. TU CKM A N: The cask is sicked up and 25 p laced into the ?co ,ce r oart of the Cark H a ndling A r e a.

EVELYN SERGER ASSOCIATES. STENOTTPE REPORTING SERVICE. CHAMLCrTTE NORTM CAROUNA

i Tuckman, Snow, Green - Direct 109 1 Q By " picked up"?

\

2 M R. TU CKM AN: By the 12 5 ton crane.

3 Q How much is the cark raised?

4 MR. TUCKMAN: Just a few inches.

5 Q There is very little m a r gin for error here ,

. 6 is there not? I' mean you only have a foot or two 7 of water above the top of the cask.

8 MR. TU CKM AN: It is not that critical 9 because there will be nobody'in that particular area 10 when you are lif tin g it.

~

11 Y'o u wouldn't wa nt to lift it out of the wate r; 12 you would lift it a few inches.

13 Q What procedures or fixtu r e s, f acilitie s ,

14 insure that the cask is not lif t ed out of the water 15 with the head remo ved ?

16 M R. T U C KM AN: Your procedures would 17 specify you would probably need to check the M cG uire l 18 procedures, but they would s p e:if y to lift this cask a 19 few inches.

20 Q It is an a d minis tr ativ e procedure?

21 MR. TU CKM AN: Yes.

22 Q Is there a physical ba rrie r or stop or 23 fi::tu r e' tha t would p r e ve nt' th e crane operator f rom i

24 r ai s in 5 the uncapped cask out of the wate r ?

l 25 MR. TU CKM AN: The hoict can only go so j EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROuMA l

Tuckman, Snow, Groon - Diroct 11 0 1

high because the lif tin g fixtu r e, the extended lif tin g 2

fix tu r e, is relatively long so the crane can physicall y 3

o nly go so far; but I don't have any idea what the 4

dim e n s io n is right now.

5 M R. GREEN: T his is M ik e Green again, 6

I don't know that dim en s io n, but the extended lif t e r 7

li mit s the heights you can lift this cask.

8 Q Such that it cannot be p hy s ic ally raised 8

above the surface of the w a t e 'r ?

10 MR. GREEN: I don't know that elevation, II but it is limit e d .

12 O Is that a design feature of the extending I3 li f tin g fixtu r e ?

I4 MR. GREEN: One of the design f e atu r e s.

15 Q So you b e lie ve that the de sign feature 16 p r e ve nt s the cask with lid removed from being raised I7 above the water le vel at this same-- -.

I8 MR. TU CKM AN: I don't know that, I would I8 presume that.

20 Q To the best of your knowledge then, it is 91

~

an ad mini s t r a tiv e procedure that limi t s this function?

22 MR. T U CKM AN: I would have to say yes.

23 as far as a c tu ally breaking the surface of the water.

t i s 24 Q D e s c ribe the c o nfi gu r a tio n of the plat f o rm 05

~

and the b dt o m of the cask area over which the cask l

EVELTN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. PeORTH CAROUNA 1

Tuckman, Snow, Groen - Direct 111 1 mu s t transverse in order to be lowered i n t o 'th e' deep er 2 p o r tio n.

3 MR. TU CKM AN: It is a smooth, horiaontal

~

4 surface.

5 Q 1s there a lip or barrier of any s o rt that

. 6 the bottom must b 'e raised above in order to range to 7 the deeper area?

8 MR. TU C KM A N: No.

9 Q How much v e r ti c a l' 'li f t in g then is r e q u'i r e d ,

10 if any, in order to transverse the cack into the 11 deeper areaf 12 M R. TU CKM AN: That is vir tually a matter

(__

13 of inches.

14 Q Then proceed, what happens then ?

15 MR. TUCKM AN: The cask is moved over 16 to the deep end or it'is lowered to the bottom.

17 Q A nd a p p r o xim a te ly how much wate r then 18 would be above the top of the cask? ,

, 19 MR. TU CKM AN: Roughly 40 feet, not over 1

20 the top, I'm sorry--

21 Q Forty feet deep total?

22 k R. TU CKM AN: Yes, excluding the height l

23 of the cask.

t 24 Q A nd a p p r o xi m a t ely how much above the top 25 of the cask?

EVELYN BERGER ASSOCIATES. STEhCTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROL #NA

1 Tuckman, Snow, Groen -

Direct 11 2 7

y" ,

1 MR. GREEN: A pp r o xi ma te ly 25 feet on top

(.

2 of the c a s k.

3 Q 'A g a i n , depending upon the a c tual c o n fi g u -

4 ration of the cask?

5 h R. GREEN: Yes, sir.

. 6 Q N ext ?

7 MR. T U CKM AN: Next the cask lif tin g 8 adapter is disconnected and removed.

9 Q How is it r e m o v e d ?'

10 h' R . TL CKM AN: I'm not sure of the 11 s pe cific c o nfig u r ation of that p a r ticula r tool, how it 12 is dis co nn e c te d.

(- 13 Q It is remotely done, does somebody need to 14 use some kind of tool that is lowered into the pool 15 and lo w e r e d into the water and a tta ch e s --

16 MR. TU CKM AN: No, I b e li e v e it is part 17 of the lif t in g fix tu r e, it s e lf.

18 Q A ll right, next.

19 MR. T U CKM A N: One of th e R e e pon s e s to 20 the Interrogatories, Numbe r Eight, indicated that the 21 weirgate is in place whenever the cask is handled in 22 reference to s ec tion s in the FSAR to that e ff e c t.

23 On r e vi e w of that r e c e n tly we r e alis e d the i

24 error, FSAR error, as our A nswe r is we would not 25 have that weireate in place durine the n o r m al cask EvEevN .ERGER ASSOCIATES. STENonPE REPORTING SERvtCE. CMA8tLOTTE. SuORTM CAROUNA

Tuckman. Snow, Groen -

Direct 11 3 7 1 h a n dli n g e v olu tion s .

s.

2 Q Why not?

3 h. B . Tl CKM AN: There ir no purpose.

4 Q What is the purpose of the weir gat e ?

5 MR. TL CKM AN: To dewate r the Cask

. 6 H andlin g A rea for h.' a i n t e n a n c e .

7 Q The Cask H a n d li n g Area i s what we are 8 t alkin g about now, both th e shallow and the deep are 9 c all e d the Cask H a n d li n g A r e a' ?

10 .NR. TU CKM AN: That's correet.

~

11 Q Indicate the location of the w eir g a t e on 12 Figure 9.1-2.2.

(

13 M R. TU CKM A N: It is on the top side of 14 the d r a win g there.

15 Q A ll right, I want to make reference to that 16 Interrogatory Answer again, if we c o uld correct that 17 for the Record.

18 MR. CARR: Number Eight on Page Te n 19 of our R e sponse s of October 9.

20 MR. GUILD: I don't have mine handy, 21 The weirgate la not no r mally in place?

l 22 MR. TU CKM A N: T h a t 's correct, it is 23 n ot.

e' 24 3 BY NR. GUILD:

EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA o

Tuckman, Snow, Green - Direct 114 1 Q Where is it located?

N 2 LR. TL CKM AN: The weir g at e is n o r m ally 3 etored on the east wall of the Cask H a nd lin g Area.

4 Q Is it then a free flow of water f rom the 5 cask, from the Spent Fuel Storage Pool through the

. 6 opening where the' weir gate would be located and into 7 the Cask H a ndlin g Area?

8 MR. TU CKM AN: Yes.

9 Q And the surface w a't e r level is the same in 10 both areas?

11 LR. TU CKM AN: That's correct.

12 Q A ll right now, if you would--

(

13 MR. TU CKM AN: Once the cask is in the 14 bottom of the Cask H a n dlin g Area, the next e volu tio n 15 is to pi c k the fuel a s s embly up and store it.

16 We u tili z e the fuel h a n dli n g crane, which 17 is the m o va ble crane shown on Figure 912-2, and in 18 the center of the fuel pool (indicating).

19 T hat crane is a li g n e d to go through the 20 weir gate opening and to po s itio n it s e lf over the top 21 of the fuel a s s e mbly.

22 The cable is lowe r e d, fuel a s s embly is 23 grappled and r ai s e d up into the fuel h a n d li n g m a s t.

I 24 Once it is up, it is transferred back through the w ei r-25 gate o p e ni n g to v hicheve r fu el lo c a tion we decided to EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

=

1 Tuckman, Snow, Green - Direct 115 l 1 store the fu el a s s embly in.

2 Q A ll right, what is the minimum depth of 3 water above the top of the a s s embly at the top of the 4 fuel handling crane?

5 MR. TUCKMAN: T e chnic al s p e c i fi c t. t i o n s

. 6 require us to h a v'e 23 feet of water over the top of 7 the a s s embly in the spent fuel racks prior to handling 8 fuel,, and I don't know th e actual dimension of once 9 the as s e mbly is a c tu ally up in the ma s t, from there 10 to the top of the water.

  1. ~

11 Q I am t r yi n g to follow the technical s p e cifi-12 cation that you ref er red to. Is that depth above the

( .

13 as s embly once they are stored?

14 MR. TUCKMAN: Right.

15 Q T his a s s e mbly b ein g removed f rom the cash 16 will be higher than that?

17 MR. T UCKM AN: T h at 's correct.

18 Q The water will be shallowe r?

19 MR. TUCKM A N: That's correct.

20 Q Do you have an a p p r o xim a tio n of how 21 c ha llo w ?

22 MR. TU CKM AN: Twelve feet a pp r oxi ma t ely 23 Q What procedures or fixtu r e s prevent the i

24 spent fuel a s s embly from being raised above the leve L 25 of the water ?

.mv~ ...... ..sociares. srs~orree anroari~a scavice. c=Sorre. ~om c.=ou~.

Tuckman, Snow, Green - Direct 116 7 1 f.! R . TU CKM AN: I think I' v e just mislead

(

2 you a little bit. Can we start.over a g ain ?

3 Q Sure.

4 MR. TUCKM AN: If we were picking up 5 Oconee fu el we would not use the m a s t, we would use

. 6 a B and W Spent l'uel H an dlin g Tool because th e fu e l 7 would not be compatible with the m a s t.

8 It is a manual tool which is suspended frorn 9 the east crane on the fuel ha sdling bridge.

10 Q T hi s is more than one crane?

11 1,fR . T U CKM AN: There is a crane that ride s 12 on the east. T hi s is the east, this is the 'w e s t rail, t' 13 and this is the east rail (in di c a tin g) .

14 There are manual cranes that rid e in those 15 slots in addition to th e no r mal fuel h a n dlin g crane 16 used for n o r m al o p e r a tio n s .

17 Q These are indicated as two ton, a uxilia r y 18 hoints on this fi gu r e (indic ating) ?

19 MR. TU CKM AN: That's correct. '

I 20 l Q By "m a nual tool," how do you mean?

21 1iR. TU CKM AN: It is a l o n g -h a n d l e d tool 22 which is suspended from the crane with a spring scal e 23 on it and tha t a s e em bly or thct lon g -ha ndle d tool 24 grabs the top nozzle of the fuel once it is set in plac e 25 and is locked from above the water.

EVELYN SERGEfe ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NORTM CAROUNA

\

T uc km an, Snow, Green - Direct 117 1 There le a limitation on dietance of travel 2 of the crane and le n gth of the tool, which prohibits l 3 you f rom drawing the tool beyond n o r m all y 12 feet 4 beyond the top of th e wa te r.

~-

5 Does that help any?

. e Q Yeah, how is the lif ting perf ormed ?

7 M R. TUCKM AN: With the controls on the 8 bridge. ,

9 Q U sing a mechanicale-10 M R. T U C KM AN: It is an electrically 11 d riven hoisti 12 Q , The two ton, auxiliary hoist we are talking i

13 about?

14 MR. T U CK MA N: That's correct.

15 O So the mechanical portion is simply the 16 lockin g and unlocking of the tool?

17 MR. TU CKM AN: It '. s what actually sets 18 on top and grabs the s haf t, the handle on the top, th e 19 latching m e c ha ni s m on the to p.

20 Q But the lif tin g is pe rf orme d m e cha nic ally ?

21 MR. TUCKMAN: That's correct.

22 Q And for M cGuir e you would use just the 23 fuel h a n dlin g --

24 MR. TU CKM AN: I would use the Westingho ues 25 Spent Fuel H a ndlin g Tool also.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLEFTTE. NORTM CARouNA

Tuckman, Snow, Green - Direct 118

\

, 1 Q W ould it be cus pended f rom the au xilia r y 2 hoist?

3 MR. TU CKM AN: Id e ntical.

4 Q What is the fuel h a n dlin g crane?

5 M R. TUCKM AN: That it used for h an dlin g

. 6 of fuel within the' Spent Fu e l Pool. It is a W e s tingho usc 7 type to be mo ve d from one location to another, or to 8 bring new fuel into the fuel poci or for t ra n s po rtin g 9 fuel to the Reactor Building.

10 Q Those are the normal tools. Why do you 11 use diff e r e nt tools?

12 MR. TU CKM AN: For the Oconee fu el s , the

(

13 mast is not c o m pa tible with the Oconee fuel. You us e 14 the Oconee special h a n dlin g tool.

15 To be p e r f e c tly honest, I' v e never thought 16 about moving W e s tin ghou s e fuel in--I'm not sure which 17 we w oul d use, the normal mas t or We s tinghou s e S p ent 18 Fuel H a ndlin g Tool.

19 Is m not sure.

20 Q W ould i t, make a dif f e r e nc e ?

21 MR, TU CKM AN: I don't think it would, but 22 l I really haven't looked at We s tin ghou s e fuel.

l 23 Q Then t h .e a s cembly is placed in its d e s tin a-24 i tion ?

25 MR. T UCKM AN: Storage lo c a tion.

l l

EVELYN BERGER ASSOCIATES. STENOTTPE REPORTING SERvlCE. CMARLOTTE. NORTM CAROUNA l

Tuckman, Snow, Green - Direct 119 g- 1 Q What is the basis for determining th e 2 storage lo c a tion s for the non-C a tawba fuels in the 3 C at awba Fuel Pool?

4 MR. T UCKM AN: As far as the W e s tinghous e 5 fuel goes, after we get that on site, it is b a s ic ally

. 6 no r e s tric tion.

7 It could be stored in any l o c a tio n. For th e 8 Oconee fu e l, we w ou ld have to put the spacer in to 9 s to r e an Oconee a s s embly.

10 Q D e s.c r,ib e the spacer. ,

11 IdR . TUCKM AN: There is a de s c ription in 12 the FSAR, 9124, about the middle of the page, and I 13 guess in the Interrogatory Response we have describe d 14 it to you also.

15 Q S e c tio n 9124 on Page 9.14-81-9.

16 MR. GREEN: T hi r d paragraph.

17 Q Have the spacers been f abricated ?

18 MR. SNOW: No.

19 Q Where would the spacers be located?

20 M R. SNOW: R e a lly no d e t e r min e d lo c a tio n 21 right now.

22 Q Is the re anything s i g ni fi c a nt in terms of 23 safety to th e ar rang ement' of the Catawba and n on-C at a wS)

/

24 spent fuels within the pool?

25 Who was that that answered that qu e s tion ?

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA r

,- e,- . - - . . , . - - ,,,-r.- .,,, . - , , -

,- - -.,..--.- ---. -- . -,.--,---- .,.. e. ,- . ,- .

T u c km an. Snow, Green - Direct 12 0 1

MR, SNOW: Lowell S n ow.

2 Q Mr. Snow, thank you. So then what would 3 be the basis for d e t e r minin g ultimately where to put 4 which fuels ?

5 MR. TUCKMAN: Wherever it is convenient,

. 6 Q T ypic ally what is the basis for determining 7 where you locate spent fuels in say at M cGuir e ?

8 MR. TU CKM AN: I don't know at M cGuir e.

9 Q Can you tell me g e'n e r a ll y whether you star t 10 at the far wall and fill back or is there any rhyme o r 11 rcason?

12 M R. TUCKMAN: There is no r equir e m e nt

(.-

13 where you store it for whateve r reason.

14 Q How do you keep track of where fuel 15 a s s emblie s are sto red ?

16 6 MR. TUCKMAN: We have a record of wher e 17 the a s s e mblie s are stored, both on the visual s ta tu s 18 board and on a computer p ro g r am.

19 Q Is that record s uf ficie ntly detailed to 20 id en tif y each s p e cific as sembly as to its origin and

)

21 age?

MR.

22 TU CKM AN: Yes.

23 Q Let me direct your attention to the p o r tion 24 of the process that you have described. Mr. Tuckman ,

25 or the o th e r gentlemen, that relates to the transit l EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA a

="

'r r - - ,- ,, -v--- - - - - , , - ,,--,--,------,,r,-- ,,--

T uc kman, Snow, Groon - Direct 121 I

I of the cas k from and to the cask lo adin g ar ea. Do 1 r;

2 understand c o r r e c tly that you have concluded that ther e 3

is no po s s ibility of a cask tip accident into the Spent 4

Fuel Fool?

5 MR. GREEN: T his is Mike Green; yes, tha t

. 6 is true.

7 Q A g a in, with reference to the cask drop 8

e va lu a tio n, Figure 9.1.2-4, is that and the f o ll owin g 9 fi gu r e, 9.1.2-5, do those r e ll'e c t , those figu r e s ,

10 r e fle c t the analysis th at produces th at ?

11 dR. GR EEN: Yes, those figur e s r efle c t 12 the two cask drops that could possibly end up in a

( '

13 cask going into the Spent F u el Pool.

14 Q Now just if you would, id e ntif y those two 15 postulated scenarios without d e tail s .

16 MR. GREEN: They are explained in the 17 FSAR g e n e r ally. We look at two diff er ent cases, the 18 fi r s t one b e in g the cask b ein g carried by the cask 19 handling crane, t r a v e ls at the maximum horizontal 20 50 feet a minute, hittin g the stop a b r u p tly.

velocity, 21 the cask s wingin g up and dis plac e m en t of 30 degrees 22 at that time p o s tula tin g the cable rigging snapping, 23 breaking, and the cask f a l'li n g at that p oint v e r tic ally 24 and seeing where the cente r of g r a vity li e s .

25 The second case was the d r o p pin g of the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. DeORTH CAROUNA

,-- ,.,-e- - - - , - - - ~ , r- p- m ~ - - - - - - -

w- a

Tuckman, Snow. Groen - Direct 122 1 cask further west of that wall that separates the fuel s

2 pool from the cask area such that a corner of that 3 cask im p a c t s on that wall and tends to want to flip 4 the cask over the adjacent wall.

5 A gain, by analysis of basic momentum

. 6 e qu ation s we c o u l'd show that it did not fall into the 7 Spent Fuel Pool.

8 Q A ll right, what is the as sumed cask 9 c o nfi g u r a tio n that was used l'o' r those as repr es ented 10 on those two fi gu r e s --17 feet high by 8 foot diamete r -

11 what s p e c ifi c cash is represented by that analy sis ?

12 MR. GREEN: I couldn't tell you that at

( -

13 this ti me .

14 Q Do I understand it to be a s p e cific cask?

15 MR. GREEN: It represents the largest 16 postulated ca s k that we c o u ld d e t e r mine.

17 Q Is it the he avie s t cask?

18 MR. GR EEN: H e avie s t and largest.

19 Q Now, is it true th a t the center of g r a vit y 20 is represented in both of these diagrams as in the 21 geometric center of the elevations th e r e of the casks P l

I '

22 MR. GREEN: Yes.

23 Is that also t h e' case for all casks that Q

24 s

will be employed or have been employed by Duke ?

25 GREEN:

MR. Yes, the center of g r a vit y EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA

T u c kman, Snow. G reen - Dir ec t 123 1 1 is within a certain tolerance located at the center of 2 the cask.

3 Q With or without the cack lid atta ched ?

4 MR. GR EEN: Yes.

5 Q Does the center of gravity change?

. 6 M R. GREEN: It would n ' t appreciably 7 change with the head attached or not attached.

8 Obviously it would be raised s o m ewhat vertically with 9 the head in plac e. '

10 Q Can you give me an e s timate of the r ela tiv e 11 weight of t h'e head as compared to the cask body?

12 MR. G R E EN: I could not at this tim e .

(- 13 Q T he total weight of the c a s k appr oximately t 14 MR. TU CKMAN: Twenty-five to forty tons, 15 depending.

16 Q Might th e lid weigh a ton?

17 M R. TU CKM AN: I don't know.

18 MR. GR EEN: I couldn't t ell you.

l 19 Q A nd it is your judgment that the removal 20 of the lid does not appreciably alte r the geometry of 21 the center of gravity loc ation ?

22 MR. GREEN: For'a cask drop a c cid e nt 23 in ve s ti g at ion, the head being in s t alle d on the cask is s 24 a more critical ca s e to look at.

25 R emoval of the head lowers the c ente r of

.my~ . .. . .. ociares. svenorv a a own~a s==ica. ciwom. ao= caaoua^

T uc kman, Snow, G reen - Direct 124 1

g r a vit y, causing it to fall back away from the Spent 2 Fuct P o ol.

3 Q The cack represented in the two figur e s ,

4 is that a cask with the lid on?

5 MR. GREEN: That represents a cask with 6

a lid head o n.

7 Q What is the dim en s io n of the cask area and 8

the Spent Fuel Iool U area?

9 M R. TUCKMAN: T f2 a t is a th r e e- f o o t t h i c k, 10 cast concrete wall represented in Figure 2-5..

11 g y'e e , sir; Figure 9125, how does that 12

.. particular c onfigur ation at C at awba diff e r from the 13 design configuration of the M cG uire Pool, if at a ll ?

14 MR. GREEN: The c o nfi gu r a tio n of that wal l 15 does not dif f e r. The configuration of the adjoining 16 w all s separate the cask area from the DECON Pit.

17 Those walls are four feet lo we r than the 18 c o r r e s p on din g w a ll s at M cG uir e.

19 Q Why is that?

20 MR. GREEN: I' m not sure why it is.

21 MR. SNOW: Excuse me for i n t e r r u pti n g , mu l '

  • 2 understanding is that was a design feature to avoid 03 the cask drop cccident.

04

~

Q With th e Icft wall, and I am r ef e r rin g to 25 Figure 9.1.2-5, with the left wall higher th an now at EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERytCE. CHARLOTTE. NOkTM CAROUNA

Tuckman, Snow, G reen - D i r ra c t 125 f I Catawba, the chance of the ca s k tip aceident of th e s

2 pool is increased?

3 hR. GREEN: The chance of that would 4 increase, yes.

5 Q The center of r o ta tion of the cask in a

. 6 ti ppin g a c cid e nt would be higher?

7 MR. GR EEN: Yes.

8 Q A nd the center of g r avit y of a particular 9 cask would fall over the S p e n't Fuel Pool with the 10 higher left wa ll ?

11 M'R . GREEN: I have not analyzed that for 12 C atawba.

(

13 Q Under the o rigin al design at M cG uire ?

14 h! R . GREEN: I wa s n't involved in McGuire ,

15 I couldn't t e ll you.

16 Q Do you know the answer to the que s tion ?

17 MR. GREEN: I d o n' t.

18 MR. IA C G A R R Y : I think the Witne s s i 19 mie s poke and said C atawba at the b e gin ni n g .

20 I b e li e v e the answer was given in th e 21 context of IA c Guir e.

22 h: R . GUILD: Yes, we understand it is 23 a four foot lower w a ll at C a t awb a.

24 MR. GREEN: Yes, e

25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE. NORTH CAROLINA e

Tuckman, Snow, G reen - Direct 126 1 BY MR. GUILD:

2 Q R elc ting again to the Tigure c.1.2-5, is the 3 top of the wall at M cGuir e r e fle c t e d by the ele va tio n, 4 th e non-shaded portions of the pic tu r e ?

5 MR. GREEN: Yes, the M cGuire w a ll, the

. 6 corresponding elevation at M cGuir e would be related 7 by 605 plu s 10 ele va tio n li n e .

8 Q D id the A p plic an t s take the p o s itio n at 9 M cGui r e that a cask tip accident of this sort c o uld n ' t to happen?

11 MR. MCGARRY: I will obj ect to the 12 line of que s tionin g concerning M c G uir e.

13 It is irrelevant to this C atawba p r o c e e din g, I4 M R. G U ILD : I w ould a sk the Witne s s 15 to answer the qu e s tio n.

16 MR. GREEN: I don't know about the I7 final outc ome at M cGuir e. I really wa s n't 18 involved in M cGuir e's elevations.

19 20 BY M R. GUILD:

21 Q Do you know whether or not Duke took the 22 p o s itio n such a tip accident could not occur at 23 M cGuire ?

24 MR. SNOW: It is my und e r s ta ndin g that th e M cask drop at M cGuir e had been analyzed.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROLINA

Tuckman. Snow, Green - Direct 127

_ 1 Q Did you understand the qu e s tion, do you 2 know whether Duke did or did not take the po sition 3 that a tip accident into the pool as repre sented by the 4 Figure 9.1.2-5 for C at awb a c ould n' t happen?

5 MR. SNOW: That is my unde r s tanding, that

. 6 the analysis demonstrated th at the M c Guir e in cid e nt 7 could take place.

8 Q C ould not take plac e ?

9 h: R . SNOW: Could; I think we are pretty 10 far a fie ld .

11 MR. MCGARRY: I'll clarify the 12 Record, I object to th e lin e of que s tioning;

(

13 but to clarify the R e co rd, the Record r e fle cts 14 that the cask would not tip into the pool, 15 and that was affirmed by both the Lic en sing 16 Board and Appeal Board.

17 MR. GUILD: That wa s n't the qu e s tio n ;

18 th e qu e s tion was could it happen, not woulc.

19 it happen.

20 M o m e n tum and geometry and there hav e 21 been fundamental c o nfi gu r a tio n changee, it 22 seems relative to e s t a bli s h whether or not, '

23 fi r s t, would it happen; but for that design 24 change and secondly wh e th e r th at d e s ig n 25 change le adequate to prevent itt occurren c e.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERysCE. CHARLOTTE. NORTM CAROUNA

T uckman, Snow, Groen - Direct 128 1 MR. MCGARRY: Over our o bj ec tion, 2 I will state that the McGuire record r e fl e c ts 3 that the cask would not tip into the Spent 4 Fuel Pool.

5

. 6 BY MR. GUILD:

7 Q A ll right, Mr. Tuckman, p a r ticula rly, and 8 I appreciate you leading me through that S did tha t 9 represent a complete d e s c riptio n of the cask handlin g 10 that would be involved in receipt and ultimate storage-11 of n o n - C a t a v[b a spent fuel at C atawba ?

12 MR. TU C KM A N: In a very eketchy manner, l'

13 the procedure would be much more d e t a il e d. There a: e 14 a lot of t hin g s we didn't mention.

15 Q Is there a nythin g that occurs to you that l

l 16 was not mentioned that was of significanc e ?

17 MR. TU CKM A N: That is s uf ficie nt.

18 Q What would happen, g e ntle m en, if a spent 19 fu el cask f ell into the Catawba Spent Fuel Fool and 20 that pool was at that tim e filled with assumed 21 inventor y of spent fuel, including spent fuels di r e c tly 22 b elow or dir e c tly adjacent to the wall s e pa r a tin g the l

23 pool f rom the cask storage area?

i 24 MR. M C G ARR Y: That is a h y p o t h e t i c :.1, i

M and I don't b e li e v e a basis can be e s tab -

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

'I n c k m t. n , Snow, G reen - Direct 129 1 li c h e d for that h y p o t h e t i c al, c.

2 MR. GUILD: I would ask you to 3 answer the qu e s tio n, please.

4 MR. SNOW: That a naly si s has not 5 been pe rf o rme d for Catawba.

. 6 7 BY MR. GUILD:

8 Q The answer is you d on't know?

9 MR. MCGARRN: No, I believe the 10 answer is that analyses have not been per-11 f o rmed for C a t a wb a.

12 s

13 BY MR. G UI LD :

14 Q I aeked you what would happen.

15 M R. SNOW: Do you want me to speculate?

16 Q I want you to t e ll me to the best of your 17 knowled ge wha t w o u ld happen.

18 h1 R . SNOW: I would ima gin e that a fuel 19 cask dropped into the Catawba pool with a storage 20 a s s e mbly in that r e g io n, that would r e s ult in some 21 damage to those storate a s s e mblie s f rom a postulated 22 cask drop.

23 Q W ou ld it cruch the a s s emblie s ?

24 M R. SNOW: I'm not sure thst--I d on ' t 25 y know what would happen to th em. I would accume the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA

Tuckman, Snow, Croan - Direct 130 1 would be d a ma g e d.

2 Q Is it reasonabic to conclude that a cask of 3 between 25 and 40 tons f allin g onto the t. s s e m b li e s 4 would c ruch them ?

5 M R. SNOW: I would a s s ume, yes.

. 6 O What damage could r e s u lt to those 7 a s s emblie s ?

8 M R. SNOW: A me chanic al damage to the 9 m at e rials of f abricatio n.

10 Q C ould it r e s ult in a release of radioactive 11 materials into the Spent Fuel Pool?

12 M R. SNOW: Yes.

13 O A rupture of cladding?

14 M R. SNOW: Yes. -

15 Q C on ta min atio n of the Spent Fuel Pool water  ?

16 MR. SNOW: Yes.

l 17 Q In your judgment if such an accident 18 occurred would that contaminat ton be s ig nific an t ?

19 MR. SNOW: No.

20 Q w ould any special procedures be required 21 in order to assure the h e alth, public health and s af et y 22 in that event?

23 MR. SNOW: I think tho s e procedures, yes.

24 W ould there be any special procedures to Q

25 address that?

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLDTTE. NORTH CAROUNA

F T u c hm a n, Snow, G re en - Direct 131

, 1 MR. SNOW: I think the de sign would 2 accommodate that action so the health and cafety of 3 the public is s a ti s fie d with current design.

4 Q Would the current fuel pool ventilation and 5 fil t r a ti o n s y s t em --

. 6 MR. SNOW: It is my un an alyz e d judgment, 7 yes.

8 Q It would work?

9 (hir. Sn6w nod ded his head 10 af fir m ativ ely . )

11 Q What would be the li k e li h o o d if such an 12 accident happened, what was de s cribe d happened and 13 there was a crushing of the a s s e mbli e s , would 14 c ritic alit y. r e sult ?

15 MR. SNOW: It would be my j u d g rn e n t it 16 would not result.

17 Q Why not?

18 MR, SNOW: Why is it my jud gment or w o ul d 19 it r e s ult ?

20 Q B o th.

21 }/. R . S N OW: The level of the c o n fig u r a ti o n 22 for c ritic a lit y would not be enhanced for this 23 circum s tanc e.

24 Q What would be t h e ef f e c t produced by crushe d 25 fuel a s s emblie s in the event of a cas k drop accident EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CNARLOTTE, NORTH CAROUNA o

'T u c km an, Snow, Green - Direct 132 1 d e s crib e d ?

2 2.. R . SNOW: I would only s p e culat e, that 3 h a s n't been analyzed. In other cir cums t anc e s it has 1

4 been demonstrated that the c r i ti c a li t y; would not 5 r e s ult f rom that cir cums tanc e, so on the basis of

. 6 previous inf o r m a ti on that is on the Record. I would 7 have to, in my jud gm ent, conclude that it would not 8 r e s ult in c riti c ality in the C a tawb a pool.

9 Q What othe r plants 'a'r e you f amiliar with 10 where that analysis has been p erfo rmed ?

11 hi R . SNOW: All plants with lic en s e s which 12 have c a p abilitie s to or who have analyzed fuel cask

~

13 h a n dli n g incidents.

14 Q S p e cific ally, yes?

15 M R. SNOW: Oconee a n d la c G ui r e have had 16 analyses of these types performed.

l 17 Q Why were those analyses pe rf o rm ed at l 18 Oconee and M cGuir e ?

l 19 MR. SNOW: I guess they were directed to 20 be performed or there was some higher problem for

^

21 a cask drop accident to occur in the fuel pool.

i -

22 Q Do you know the reason?

23 M R. SNOW: I t'h o u g h t I did, but I' ve been 24 directed o th e r wi s e or I'm somewhat ignorant about l

25 that. A pp a r ently the analysic was done on M c G ui r e .

L EVELYN DERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NosrTM CAROUNA l

Tuckman, Snow, Green - Direct 133 l

I

, 1 The reasons for doing it are beyond my l

2 knowledge.

3 Q Why was it done at Oconee?

4 M R. TUCKMAN: I can answer that, I was 5 Lic ensin g Engine er at Oconee when the analysis was

. 6 performed; and a t' th at tim e we were applying for a 7 lic e n s e to rerank O c o n e e . III .

8 O Are'you f amiliar with the analysis there ?

9 MR. TU CKMAN: N'o t the d e t c.11's of the 10 analysis.

11 Q In the analysis that was done at M cG uir e 12 and O c .o n c e , what was the configuration a s sumed to be  :

)

k' 13 produced by the drop onto the a s s e mblie s ?

14 MR. MCGARRY: Let me let the Recor d 15 r efle c t I objected to this lin e of inquiry 16 ten minut e s ago.

17 The fact thnt I have not been obj e c tin g 18 does not mean it is not a continuing 19 o bj e c tion.

20 MR. SNOW: It is my r e c olle c ti on tha t 21 the maximum enhancement of c ritic ality 22 potential would be the s ho vin g together of 23 a s s e mblic s f r o rn the cask drop.

24 25 BY MR. GUILD:

EVELYN SERGER ASSOCIATES. STENOTYPE REPORT NG SERvlCE. CHARLOTTE. NORTH CAROUNA

Tuckman, S n o w, G roe n - Direct 134 7

1 Q A nd what geometric configuration--

\

2 MR. SNOW: Side by side.

1 3 Q A lo n g their ve rtic al axes?

4 MR. SNOW: Yes.

5 Q What criticality enhancement would r e s ult

. 6 f r om a diagonal or a right angle inte r s e c tion of 7 a s s emblie s ?

8 M R. SNOW: Much less.

9 Q And with the m a xi rhu m enhancement you sai :1 10 was produced by the a s s e mbly being pressed together 11 a lon g their v e r tic al axes, how close to c ritic alit y 12 did the a s s e mbli e s come ?

t 13 MR. SNOW: I d on't r e c all that num b e r.

14 It was b e l o w, less than c ri ti cal.

15 Q R emaine d sub-c ritic al ?

16 MR. SNOW: Yes.

17 Q For all possible--

18 MR. SNOW: Yes.

19 Q Why ?

20 MR. SNOW: P h y s i c s.

21 Q Is the s ymmetrie s of fuel pool wate r s 22 significant to that c ond ition ?

23 MR. SNOW: I don't r e c a ll in this 24 particular instance.

25 Q The fuel pool wate r is designed for b orated-< -

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA r

Tuckmun, Snow, Green - Direct 135 1 MR. SNOW: It is.

s 2 C I< n d the b e r a ti o n is in part to reduce the 3 chance of c rit ic ality ?

4 MR. SNOW: No.

5 O b' hat is the purpose of the b o r a t i ., n ?

. 6 hi R . S N O V/ : The purpose of the bo ration ol 7 the water ir to prevent dilution during r e f u e lin g into 8 the rack to the c o o lin g s y s te m.

9 Iv. R . M C G A R R S': Are we into 10 c ritic ality now? We were talking about 11 L'. c G u i r e and Oconee and the cask drop at 12 M c Gui r e and Oconee.

13 If we have gone into another area, we 14 are at an appropriate time to take a break.

15 MR. GUILD: Just a little mo r e.

16 17 BY MR. GUILD:

18 O What is the f u n c ti o n of the boration of the 19 .v

. a t e r , eith e r in the fuel pools or in the racks e f flu e r.t?

20 hR. S N C Yl: The f un c tio n of borated water?

21 Q Yee, in the rtek to fu elin g, i t s e'1 f , docen't 22 it r; e r v e the c a r.: e function in the pool?

23 u n, snow; yes.

24 O Doesn't it reduce the lik elih o o d of 25 c ritic ality ?

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

3 Tuckman, Snow, Groen - Direct 136 1 MR. SNOW: Its presence would.

(

2 Q A nd its absence would c o n ve r s ely increase 3 the chance of c ritic ality ?

4 MR. SNOW: Yes.

5 Q What is the technical s p e cific a tio n being

. 6 e mplo ye d at C atawba for the cond en s ation of Boron 7 in the c entr al pool?

8 MR. TUCKM AN: I b eli e v e it is 2,000 parts 9 per mil; I don't r e c all the u p'p e r limit.

10 Q Has Duke ever experienced an instance whe:re 11 Boron c ond e ns ation at any of its f a cilitie s has droppe d 12 below e ith e r the rack to c o o lin g system or spent fuel ?

t' 13 MR. T U C KM AN: It sub s equ ently dropped in 14 the rack to c o o lin g s ys tem during reactor. I am not 15 aware of an instance when it dropped below technical 16 a p e cific atio n s.

17 Q How about below two parts per m il ?

18 MR. TU CKM AN: That is a technical 19 s pe cific ation.

20 Q You are not aware of any cir cum s t a nc e s 21 where the Boron has dropped below 2,000 parts per l 22 mil ?

23 MR. TU CKM AN: I am not f amilia r with 1

24 O c o n ee, l

25 l Q G entle men, do any of you know of any l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA

Tuckman, Snow. Green - Direct 137 1 in s tance ?

2 MR. GREEN: M ik e Green, Iam not eithe r, 3 MR. SNOW: I am not f amiliar with an 4 instance.

5 Q Either in the fuel pools or any other Boran

. 6 storage tank o r make-up wate r tank or any other syst em 7 where eith e r under normal conditions or ac c o r din g to 8 textuals, the 2,000 parts per mil standard would 9 apply?

10 MR. TU CKM AN: I don't u n d e r s t r. n d the 11 que s tion.

12 O I have understood there may have been an ,

1 13 instance at one of Duke's f ac ilitie s in some portion 14 of the f a c ili ty, s. n d I .m trying to understand whe n 15 and where or if I am correct, w h e re Boron 16 c onden s ation dropped below 2,000 parts per mil; and 17 help me, if you can think of s o m ethin g, and I am not 18 u sin g the correct technical terms.

19 MR. TU CKM A N: Oconee had an instance, 20 and I can't r e c all where or when, in which B or at ed 21 or Bo ra tion s p e cific a tion s were below the s pe cific atio n, 22 but I can't r e c a ll where or when.

23 Q And that would be on the 2.000 parts per 24 mil standard ?

25 M R. TUCKM AN: Yes.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERvlCE. CNARLOTTE. NOsrTH CAROUNA

T u ckman, Enow, G roen - Direct 138 1 Q Do you know how or where that happened?

l 2 M R. T U C IO.: A N : I don't know.

3 MR. GUILD: All right, C ou n s el, this 4 has been going a long time. I think I can 5 fini s h up quickly, if you will bear with me

. 6 a little ~ bit.

7 8 BY M R. GUILD:

9 Q Let me turn very briefly, if I can, to the 10 Spent Fuel Pool cooling s y s te m. Is it e s s e n tially 11 correct that the fuel pool cooling system as in s t alle :1 12 at C atawb a l's th e same design s ystem a s was original ly 13 proposed for the s m all e r capacity pool?

14 M R. TU CKM AN: That is e s r entially correc t.

15 There were mino r m odific a tion s.

16 Q With those minor m o dific atio n s , were they 17 imp o r ta nt to the f u n c tio n s of the c o olin g system?

18 MR. T U CKM AN: No.

19 Q Is n't it e s s e ntially true that the '7 6 heat 20 load, increased heat load analysis, is the basis for 21 your c o n c lu s io n that the originally de signed pool 22 c o olin g system will function adequately under the add e'd 23 heat l o r. d s of n o n - C a t a wb a~ fuel pool as s e mblie s ?

24 M R. SNOW: Yes, that is correct.

25 Q In lay terme, g e n tle m e n, how much is the EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CARCE.fMA

, , ,m...- - . . , . - - - -- -- m n - -

Tuckman, Snow. Groon - Direct 139 l

1 heat removal r equir e m ent at the expanded C a tawba poc le s

2 enhanced beyond th e hect load expected at Catawba  ;

3 prior to its redesign and exp an sion ?

4 L R. SNOW: What ? Are you a s kin g for the 5

diff e renc e in the quantity of heat, the analysis that is 6

p re se nted in this document gives two v alu e s for a ll 7

C atawba situations and one for an as sumed amount of 8

material f rom other plants.

9 Q Yes, sir.

10 M R, SNOW: Do I understand your qu e s tio n 11 to be what is the diff e re nc e between those two nu mb e r s?

12 Q No, the que s tion is what is the dif f e renc e t

13 b e tw e en your o r i g in a ll y expected--I am not talking 14 about the design range, but the expected no rmal remo val 15 value a nd the value that is postulated for use at Cata .v b a 16 as expanded to include the non-C a tawba fuels.

II MR. MCGARRY: I would object to tha .

t I8 lin e of qu e s tio nin g. I b elie v e we were into 19 this lin e of qu e s tionin g e a rlie r, and th e l oo

~

basis for the objection le the status, the 21 design, the heat lead c a pa bilitie s of the 92

~

o rigin al design at Catawba Spent Fuel Pool 93 is irrelevant to the p r e s en tly designed 24 C atawba Spent F uel _ Pool.

25 M R. G UI L D : I would ask vov to answ 3r EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. MORTH CAROLINA

Tuckman, Snow, Green - Dircet 140 1

the qu e s tion, please.

f 2 MR. SNOW: We would have to do a 3 lot of adding to fi gu r e that out. The 4

current or the 1976 d o cum e nt a s s um e s , and 5 it is in the FSAR there, B42.7, B.T U.s

. 6 for heat generated for the m axi mum --

7 If I could call it multi-unit c o nfi gu r at ion 8 Pool.

9 MR. GUILD: 'Yes.

10 MR. SNOW: With C :. t a w b a pool only 11 the number is in the order of three m illi o nk 12 , MR . G UILD: Okay, B.T.U.s?

i 13 MR. SNOW: Yes. But that in clud e s 14 some as sumed Catawba fuel passed th e 15 o rigin al, about 700; and you would have to 16 look on the values to de te rmin e th at , but i t

! 17 would be s m all.

18 But the additional fuel expansion did i

l 19 not rn a t e r i a ll y increase the heat load f r om 20 C at awba fuel.

21 22 BY M R. G UI LD :

r 23 Q But the order of m a gnitud e is within the f 24 range of 39 to 457 l

25 MR. SNOW: Yes, 39 to 42 mit B.T.U.s.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE, NORTM CAROUNA

Tuchman, Enow, Groes . Direct 141 7 1 Q Now the design of the Spent I'uel Pool 2 o r i g in ally was on the basis o f the a s sumption that the 3 pool would be used only for short term decay and the a 4 p r o p e rti e s transchipped to a reporsessor, r e po sit o r y, 5 is thr.t correct?

. 6 ht R . SNOW: Not particularly.

7 Q Did you understand that the original pool 8 design was for long term, on site storage of spent 9 fuel?

10 MR. S N O V/: The heat load a naly s is is 11 dominated by the fuel core discharge.

12 Q Yes, I understand your position there; but

/

Wouldn't you agree 13 let me repeat the qu e s tion again:

14 that the original design of the f a cility wa s for the 15 expected normal operation which would include use of 16 the pool only for temporary decay and then properties 17 t r an s s hipp e d ?

18 hi R. S N O V/ : That is imm a te rial.

19 Q Isn't that true?

20 MR. S N O VI: I don't know whether it is tru e 21 or not; it is i mm a t e rial to the analysis is my point.

22 The analycic does not m s. k e any dif f e r e n tia tio n there.

23 It a c cume s the fuel pool full of a s s e mblie s

' 24 and therefore it cannot speculate rbout what may or 25 inay not happen to the m at e rial.

evetm nr.onn associares. svawones aseo=rimo suavice. cuaatorra. wo=ra caaouwa

Tuckman, Snow. Groon . Diroct 142 1

Q The o ri gin al a naly s is for the design of the 2 C at awba S pe nt Fuel Pool prior to its expansion assum ed 3

a f u ll pool?

4 M R. SNOW: Sure.

5 Q A nd hottest fuel?

6 SNOW:

M R. Yes.

7 Beyond that, is it your understanding then Q

8 that beyond the physical expansion of the dim e n sio n s 9

of the pool and therefore its 'c a p a c i t y , no alt e r atio n s 10 were eith e r necessary or have been rnade to the 11 S pe nt Fuel P ool coolin g system?

12 M R. SNOW: That's correct.

L 13 Q Do any other systems significant to safety- -

M MA. SNOW: The Spent Fu el Pool v e n tila tio n 15 system was increased in capacity due to the larger 16 volume of air mas s in the fuel pool area.

17 Q I direct your attention to this do cument, ,

18 the '76 heat lo ad study.

19 MR. SNOW: A ll right.

20 Q L o o ki n g at Page Two of Thirty, does that 21 note accurately r e fle c t the current dimen sion s of the 22 pool at the bottom of the page?

23 MR. SK C W: A p'p r o xi m a t e ly tha t 's correct.

24 yes, sir.

25 Q What is the basis for the dif f e ren c e betwee n EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA

Tuckman, Snow, Groon - Direct 14 3 1 the 1,412 a s s embly capacity r e fle c t e d on Page 5 of 2 the EO study and the s p e c ifi c a tio n s that are currently 3 referenced, 1,418 now in the FSAR?

4 MR. SNOW: I'm not sure I know the 5 dif f e r e n c e .

. 6 MR. TUCKM AN: The dif f e r enc e is six.

I 7 Q Thanks. Was the 1,412 intended to be an j g a p p r o xim a tio n ?

9 MR. SNOW: I think it is an a p p r o xim a tio n, 10 Q The 1,418 is a firmer fi g u r e in terms of

~

11 actual cap acity ?

12 M R. TU C KM AN: Yes.

l '

13 Q What happened to th e Spent Fuel P o ol liner l 14 plate if the temperature design limitations are exceed e d ?:

15 M R. GREEN: The line r plate, w e ll, it is l

16 designed for t empe ratu re s s p e cified in the FSAR. If 17 those temperatures are exceeded, is that your qu e s tic.n?

18 Q Yes.

l 19 MR. GREEN: You would have more of a 20 tendency for d ef ormation of the water, the lik e lih o o d 21 of ma re degrees being a p p lie d to the w e ld s , to the 22 base plate bedded in the concreta. '

23 Q What would happen if the lin e r plate welds, 24 if the lin e r plate deformed or w eld s , d ev elop ed crack s 25 or breaches?

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NOMTH CAROUNA

T uc kman, Snow, Green - Direct 144

, 1 M R. GREEN: What would happen?

2 Q yes, 3 MR. GREEN: If the li n e r plate was to 4 expand it would how out further from the concrete 5 surface.

6 If the welds were to crack, which I' m not 7 sure they w ould, if they were to crack, I don't know 8 of any significant consequence at this time.

9 Is the lin e r significant to m aintainin g, io Q

10 preventing leakage from the spent fuel?

11 1,. R ,

. GREEN: There is a leak chase outsid a 12 of the weld s that connects the lin e r pinte to the base 13 plate.

14 That w o ul d n ' t crack under any t e mp e r atur e s .

18 B elow the pool?

Q 16 3.: R . GREEN: No, it is outside the pool on 17 to p of the line r plate. -

18 Next to the line r plate?

Q 19 hi R . GREEN: I' m trying to find a way to 20 There is opent fuel water to d e s c rib e it to you.

21 come in contact with the concrete su rf ace behind the 29 ~

liner p l e.t e , two diff er ent welds would have to crack 93 and develop icaks.

94

~

Is it a double li n e r ; is that what you are Q

25 a aying ?

avt:tyn ennaan associates. stenorvas necoarino senvice.cuantorra.nonra canovna l

Tuckman, Snow, Groen - Direct 145 1 MR. GREEN: Yes, at the joint there is a 2 doubic lin e r .

3 Q At the bot tom of the pool, s id e s of the poo l?

4 .V R . GR EEN: A ll surfaces of the lin e r 5 plate.

. 3 Q Is this an annulus ?

7 MR. GREEN: An annulus, if you will, that 8 surrounds the joints, the y are welded up to the water .

9 T hat weld is an a nnulu s curro'nding u the w e ld.

10 It runs the length of the pool.

11 O It is cn angle, a structural, stainless stee'l 12 angle thst sets down over the weld and w eld e it down 13 to the lin e r plat e ?

14 L R. GREEN: On the wat e r s id e of the lino r 15 plate. ,1 -

i 16 Q Incide the pool there are angle irons?

17 A. R . GREEN: Yes, tu r nin g it upside down 18 you would look Ilk e a toepee.

19 Q If the int e g rity of the line r was b r e t. c h e d ,

20 would the pool water leak?

21 14 R . GREEN: I don't know.

22 Whe r e would it go if it got through the O

23 line r ?

24

?,t R . GREEN: It would come in contact with 25 the concrete s ur f ac e.

EVELYN SERGER ASSOCIATES, STENOTYPE REPORTING SERVICE. CHARLOTTE. NOWTH CA'touNA

i Tuchman, Snow, Green - Direct 146 f 1 Q Is that concrete s e s. l e d ?

s 2 h R. GREEN: No.

3 Q W ould it drain through cracks in the 4 concrete ultimat ely ?

5 g. R .

. GREEN: Cracks in the e xi s tin g

. 6 concrete?

7 Q Joints in th e concrete?

8 GREEN:

M R. Pores, yes; if cracks did

~ '

9 f o rm, yet, that is a p o s sibility.

10 Q M c. s the company p e r f o rme d any analysis 11 of postulated leake in the Spent Fuel Pool?

12

,. hi R . GREEN: No.

13 Q Has the company performed any analyses 14 to determine how much expneure at what temp e ratur e s 15 beyond the de sig n limitations the pool liner could 16 with s t a n d before its in t e g rity was thr eate ned ?

17 A R. GREEN: I' m not f a milia r with Oconee ,

18 I couldn't answer the qu e s tio n.

19 Q For C atawba ?

20 MR. GREEN: Repeat the qu e s tio n.

21 Q Has any analysis been pe rf ormed of the o9

" ~

e ff e c t s cn the lin e r plate of exceeding th e temperatur e 23 design limit ation s ?

\ 24 MR. GREEN: We have no calculations goin g 25

'hevond 150 degrees.

EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CMARLOTTE. NORTM CAROUNA

T uc hman, Snow. Green . Cross 14 7 1 Q That analycle has been p e r f o rm e d of the s

2 effects on the in t e ;; r i t y of the Spent Fuel E uildin g of 3 impacto from an airc raf t crash?

4 MR. MCGARRY: We object to that 5 que s tion, and we would direct the Witn e s s

. 6 not to ans we r that que stion.

7 That area was raised in a C ont entio n 8 by P a lm e t t o A lli a n c e w hi c h was r ub s equentl y 9 rejected by the B o a'r d .

10 MR. GUILD: We desire the Witnes s 11 to answer the qu e s tion.

12 MR. M CG ARR Y: And we instruct the 13 Witne s s not to answer the qu e s tion.

14 MR. GUILD: That c o nc lud e s my 15 qu e s tion s.

16 MR. M CG A RR Y: I just have s e v e r al 17 f o ll ow up qu e s tio n s. I direct this to the 18 Panel.

19 20 CROSS E X A I.I IN A T I O N 21 EY MR. M CG ARRY:

22 Q A re t ranc e hipm e nt s between the C a tawb a 23 S p e nt Fuel Poolc c o n t e m pla t e d ?

24 MR. SNOW: Setween the pools?

25 Q T ha t's correct.

EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLDTTE. NORTM CAmouNA

Tuckman, Enow. Creon - Croes 148 g I h: R . TE CKMAN: I don't know of any.

(

2 MR. SNOW: Not to my knowledge, no.

3 Q With respect to the inquiry c on c e rnin g the 4 p eo ple who would be u tili = e d in u nlo a din g the spent 5 fuel casks, I b e li e v e his area of inquiry was directed

. 6 to Mr. Tuckman; 's i it necessary for Duke Power Com pan 7 to hire additional pe r s onnel to conduct this a c ti vity, 8 or will th e personnel necessary to conduct this 9 a c tivi ty be drawn from a poo1'already in existence at 10 the Catawba plant?

11 MR. T U CKM AN: If this a c t i vit y were to 12 c ontinu e at rates we talked about e a r li e r , we would 13 still u tili = e personnel f rom the e xis tin g resources.

14 but we would have to increase th e m a na g e m ent a t' th e 15 s tatio n to accommodate that le vel of activity.

16 Q What additional s t a f fin g would be required?

17 M R. TUCKMAN: The maximum stipulated 18 300 s hip m e nt s per year, I would think that we would 19 wind up with at le a s t one additional O p e r atio n s 20 Supervisor, two Equipment O pe rator s, and that is 21 probably it.

22 MR. MCGARRY: Okay, that is it, 23 g e ntle m e n.

k 24 FURTHER THE DEPONENTS SAITH NOT .

25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTM CAROuma

149 1

r I, Lichael T u c km a n, hereby c e r tif y that I have s

2 read and understand the foregoing transcript and 3 b elie v e it to be a true, accurate and complete 4

t r a. n e c r i p t of my t e s tim o ny.

5

. 6 7

Michael Tuckman 8

9 This D e p o s ition was s i g n'e d i n my pres ence by 10 Michael Tuc kman on the day of June, 1983.

11 12 f

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13 Notary Public 15 16 17 18 19 20 21 22 23

(

N 24 25 EVELYN BERGER ASSOCIATE $. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

150

, 1 I, Lowell Snow, hereby c e rtif y that I have read

(

2 and understand the f or e g oin g transcript a nd b elie v e it 3 to be a true, accurate and complete transcript of my i t e s ti mo n y.

5

. 6 7 _

Lo w e ll. .S n o w 8

9 This D e p o s ition was s i g n'e d in my pres ence by 10 Lowell Snow on the day of June, 1983.

11 12

(

i 13 Not a r y Public 14 15 16 17 18 19 20 21 22 23

( 24 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE NORTM CAROUNA

151

, 1 I, Michael Green, hereby c e r tif y that I have rea d

(

2 and understand the foregoing tr an s c ript and b eli e v e it 3 to be a true, t. c c u r a t e and complete transcript of my 4 t e s timo ny.

5

. 6 7

Michael G reen 8

9 This D e p o s iti on was signed in my presence by 10 Michael G re en on the day of June, 1983.

11 12 t'

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13 Notary P u blic 15 16 17 5 -

18 19 l

20 21 22 23 I

s 24 25 EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAmouMA

152

, 1 C E R T I F I C A T E

's 2 STATE OF MORTE C A RO LIN A 3 COUNTY OF MECKLENBURG 4 I, L ynn E. G illi a m , do hereby c e rtif y 5 that the proceedings were by me reduced to m achine

. 6 c h a rthand in the presence of the Wit n e s s e s, af t e r wa rd a 7 transcribed upon a typewriter under my d ir e c tio n; and 8 that the foregoing is a true and correct transcript 9 of the proceedings.

10 I further c e r tif y that these proceedini;s 11 were taken at the time and place in the foregoing 12 c a p tio n s p e cifie d.

\

13 I further c e rtif y that I am not a 14 relative, Counsel or /. :t o r n e y for eithe r Party or 15 o the r wis c inte re s te d in the outcome of this action.

16 IN WIT N E S S WHEREOF, I have here-17 North C ar olin a, unto set my hand 'a t C ha rlo tte, on 18 this the day of June, 1983.

l 19 20 21 l

22 LYNN B. GIL LI A M 23 Court Reporter

$ 2/.

25 7.. y C o m mi c c io n expires Id a y 12, 1988.

l l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUNA

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